Last Updated: December 13, 2019
INTRODUCTION TO AUDIENCE ACUITY’S SERVIES
Audience Acuity, Inc. (“Audience Acuity” or “We”) helps marketers and advertisers (and their clients) target their advertising and content to consumers who are most likely to consider them relevant and interesting, based on those users’ interests and demographics. We provide data services to marketers engaged in analytics, enrichment, direct mail, online display media and email marketing, as well as other data services.
Audience Acuity adheres to the widely adopted self-regulatory standards and principles set forth by the Direct Marketing Association (DMA), the Digital Advertising Alliance (DAA) as well as the Network Advertising Initiative (NAI).
To do a universal opt-out of all of Audience Acuity’s databases, please click here
THE TYPES OF DATA THAT WE OBTAIN AND USE
Audience Acuity receives data from a variety of consumer-facing companies and services, and data compilers and suppliers. We also obtain data through public sources, such as census data and other public records. Some of the data we use and make available is Personal Information (“PI”) or is linked to PI. PI includes, for instance, name, postal address, telephone number or email address. In addition, some of our services involve using and making available “business to business” data, which is obtained from several sources, including public directories, filings and publications, surveys and subscriptions.
Audience Acuity does not collect or use individual social security numbers, banking information, or information that we know was collected from persons under eighteen (18) years of age. We accept, but do not store, credit card numbers for payment processing.
HOW WE USE PERSONAL DATA
We use Personal Information for various purposes. We use it to create “audience data” – categories of personal interests that are grouped together based on common interests or preferences (“Data Segments”). These Data Segments may identify a person or, when used online, a unique online identifier, as, for instance, enjoying sports, travel, living in a middle-class neighborhood, or having children. By permitting marketers to incorporate this information into how they send offers to their customers and others, it is more likely that marketers will send relevant and desired, rather than unwanted (and potentially annoying) offers, coupons and ads.
We offer these Data Segments, in different forms, to marketers wishing to reach customers through online (e.g., web/mobile), email, and offline channels.
Using similar technology, we also help marketers to reach their own “CRM” lists – their proprietary “first party” lists of their own actual and prospective customers, along with their proprietary Data Segments. We help marketers reach audiences representing these lists through display media (for instance, working with partners that de-identify this data), email and direct mail channels.
THE SERVICES WE PROVIDE TO MARKETERS AND ADVERTISERS
More specifically, we use Personal Information and Data Segments to provide the following services:
a. Traditional Data and List Services. We use and make available to marketers PI and Data Segments, and work with marketers’ in-house data in order to help marketers target direct mail and other advertising campaigns and to analyze and understand their users;
b. Email Services. We use and make available PI and Data Segments and work with marketers’ in-house data to help marketers target and analyze email campaigns. Our contracts making available email-based data services prohibit a wide range of illegal, inappropriate, and offensive advertising and content, and require strict compliance with CAN-SPAM and other email best practices;
c. Providing online marketing services (“Online Ad Services”). We work with other data distribution and online cookie networks to de-identify Data Segments for use with anonymous online cookies (or similar technology), so that marketers can send display media to users across web and mobile platforms in a privacy-sensitive way. Further, when we help marketers target anonymous offers in this way, we do not place personal information into cookies, and only collect anonymous web browsing information (or tie that information to PI), and we require our data partners to similarly respect consumers’ privacy. We do not use, or authorize other cookie platforms to use, “Flash Cookies” or locally stored objects for purposes of ad targeting. The Data Segments used for this may be comprised of Audience Acuity’s own proprietary data (such as when a customer wants to send ads to, e.g., sports fans or travel enthusiasts) or may be our customers’ own proprietary data (such as when a customer wants to send special offers to its own customers).
In addition, we may help these customers to measure the effectiveness of display media campaigns – for instance, to determine which types of ads are most likely to be seen or opened by which types of customers, or which types of ads are most likely to lead to purchases. When we do this, we respect privacy as set forth above.
d. Other Data Services. We sometimes use PI to provide other data services, such as verification, record look-ups, anti-fraud, and other analytics and database tools.
e. Providing or Assisting in Cross-Channel Marketing. We may use PI and Data Segments to help marketers and other data platforms in “cross-channel” marketing – analyzing, locating and creating potential marketing “audiences” through multiple channels, e.g., web and mobile.
f. Improving of Our Own Products. We may use certain PI and Data Segments to improve, analyze and develop our own products.
HOW WE RESPECT CONSUMER PRIVACY
Consumer privacy is of paramount concern to us. We respect user privacy in the following ways, which we believe meet the highest of industry standards. In addition to other privacy and security protections discussed in this Policy, we adhere to the following:
a. As to our online marketing services, we avoid placing personal information into cookies, and when working with data partners we irreversibly “hash” into non-human readable, de-identified form any personal information they receive from us, before using or sharing it for ad targeting purposes. In recognition of the importance of fully separating online data (e.g., browsing data) from personal information, we employ other, sophisticated technical means to fully segregate databases containing PI from online data, e.g., campaigns that track user conversions.
b. As to our email products, in addition to requiring strict compliance with CAN-SPAM and advertising and content guidelines, we permit users to opt-out of the Audience Acuity email database directly through all campaigns we host;
c. As to all data segments we offer, we do not work with financial or insurance account information, social security numbers, or information about individuals’ health or ailments;
d. We provide multiple opt-out channels, as described below in Section 6.
e. We contractually require our online partners to provide appropriate notice and choice to their own customers and users.
YOUR OPT-OUT RIGHTS
You may click here to send an email to us, to opt out of Audience Acuity’s database. If you do so, please include the following information in your email: (a) first and last name, and (b) current address. You may also provide us with other addresses you have lived at during the previous five years, which may help us to opt you out even if we have not yet acquired your current address information. If you decide to opt out in this way, we will stop using data in Audience Acuity’s proprietary database to help our customers send or tailor ads and content to you, including through email, direct mail or online display marketing. Doing so will not opt you out of our Clients’ databases, only data in Audience Acuity’s own database – so other companies that we work with may still send ads, offers and content to you. We may also retain certain information for products that involve risk, compliance or anti-fraud measures.
Opting Out of Online and Mobile Targeting. If you wish to opt out of other third-party ad platforms and ad networks (including ones we work with and may have transferred data to in the past), we recommend visiting the opt-out pages offered by the Network Advertising Initiative and https://www.networkadvertising.org/mobile-choice/ , as well as the DAA’s AboutAds program andhttps://youradchoices.com/control . Opting out through the above methods will cause one or more opt-out cookies to be set on your browser or device, to indicate that you have opted out. Opting out in this way won’t prevent you from seeing ads: but it will in many cases lead the companies listed to stop customizing ads based on inferences they have made about you or your interests. Also note that these “opt-outs” are browser-specific, so opting out on one browser will not affect a second browser or device that you use. Thus, if you buy a new device, change browsers or clear all cookies, you’ll need to perform this opt-out task again.
HOW WE WORK WITH AND SHARE DATA WITH THIRD PARTIES
Audience Acuity may share data, including Personal Information, including PI and Data Segments, with agents and service providers who work on our behalf, or to help us provide services requested by our customers. We may do so, for instance, for analytical purposes, to measure campaigns, or inform future campaigns. We may do so to facilitate the sending of display media, email, or other requested services. These agents and service providers do not have an independent right to use or share any Personal Information.
Partners: We may share data, including PI and Data Segments, with business and data partners to help provide more tailored advertising and for analytical purposes. However, Audience Acuity does not share PI with ad networks, i.e., platforms that serve advertising on other, third party websites.
Affiliates, Parents and Subsidiaries: Audience Acuity we may share some or all of the data in our possession with affiliated or subsidiary companies.
As Required by Law or to Protect Any Party: Audience Acuity may disclose data if we believe such disclosure is necessary to (a) comply with relevant laws or respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Audience Acuity or any other party.
COOKIES THAT WE USE
- After you have visited certain pages on our website, cookies enable the site to ‘remember’ that information. Cookies and other passive information collection technologies enable us to deliver content that tailored to interests, browsing history and preferences based on your site activity.
- Cookies and other passive information collection technologies enable us to compile aggregate statistics concerning use of the site, analyze trends, and otherwise administer the site.
SENSITIVE INFORMATION, AND INFORMATION PERTAINING TO CHILDREN AND HEALTH CONDITIONS
Audience Acuity does not offer Data Segments containing or identifying personal information, financial records, health conditions or medical ailments, or data that we know (or learn) is obtained from children under eighteen (18) years of age. This only applies to the data that Audience Acuity itself directly provides – our customers, data partners, ad networks or other platforms with whom we work may use or make available their own, distinct sets of data.
SECURITY AND DATA INTEGRITY
Audience Acuity takes significant steps to help ensure that the data we possess is housed and transmitted securely. We use multiple layers of physical and electronic security, including firewall protections, encryption of data during transfer, and strict access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ multiple, substantial efforts to ensure that this does not occur.
EU-U.S. PRIVACY SHIELD FRAMEWORK (INDIVIDUALS IN THE EU)
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Audience Acuity is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Audience Acuity’s accountability for Personal Information that it receives under the Privacy Shield framework and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Audience Acuity remains responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process Personal Information on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Audience Acuity commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact Audience Acuity by email at firstname.lastname@example.org.
Audience Acuity has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
QUESTIONS OR CONCERNS
If you have questions, concerns, or complaints about Audience Acuity’s privacy efforts or data products, please contact us at:
10845 Griffith Peak Dr. Suite 200, Las Vegas, NV 89135
Or, you may email us at email@example.com