The Data Network (“TDN”), and its U.S.-based affiliates 180byTwo LLC and RCH Data LLC, respect and are committed to protecting your privacy.
As part of its commitment to privacy, 180byTwo adheres to both the DAA Self-Regulatory Principles, eDAA’s European Principles for Online Behavioral Advertising and adheres to the NAI Code of Conduct.
180byTwo does not provide products or services directly to consumers. Instead, 180byTwo has products and services that help businesses – marketers, advertising agencies and publishers – engage in interest-based advertising. Interest based advertising is the practice of delivering relevant content and advertising to people based on their interests, activities, and behaviors. Note that when providing interest-based advertising services to its clients, 180byTwo does not use information that we deem to be personal information, which is information that identifies you as a specific person (such as your name, address, email address, or phone number), but we may use de-identified personal information as further described below.
180byTwo has the following products and services, which are collectively our “Services”:
Some of 180byTwo’s services, including the 180byTwo Audience Suite, allow 180byTwo clients to reach the right online audiences for their products and services. To provide these services, 180byTwo licenses online data from third party data providers (including website owners, app owners, data aggregators, and SmartTV manufacturers) and makes this data available to its clients. This data is called “Third Party Data”. 180byTwo’s clients use this Third Party Data to create data segments associated with certain interests, behaviors, and attributes (for example, an interest in travel or an interest in sports). These data segments are associated with cookies and advertising identifiers, so that clients can send relevant advertisements to consumers on their computers, phones, and other mobile devices.
180byTwo has software to provide services and products, including the 180byTwo Audience Management Platform (“AMP”), that 180byTwo licenses from other Third Party Partners. These products assist our clients in collecting and organizing information about their customers from their own sources – including client websites, mobile applications, advertising campaigns, CRM systems, and data partners – and then using this information for digital advertising purposes. 180byTwo provides the tools and services that facilitate our clients’ collection and export of this data (called, “First Party Data”) and 180byTwo acts as a service provider in processing this data at the direction of those clients.
180byTwo has additional products and services that help clients use data to deliver personalized content and advertising to users both online, via computers, phones, and other mobile devices, and offline, via more traditional marketing methods. For example, 180byTwo helps clients to bring data that was collected offline into the online space, where it can be used for digital advertising purposes; and 180byTwo helps clients to identify relationships across computers, phones and other mobile devices, so that a user can benefit from targeted advertising across multiple devices.
180byTwo collects information directly. 180byTwo also collects and receives information on behalf of its clients and receives information from third parties for use in its Products and Services. 180byTwo collects information via many methods, including cookies, pixel tags, SDKs (software development kits), secure file transfers, and server to server connections.
When we refer to Personally Identifiable Information (“PI”) in this policy, we mean data which identifies you personally using an identifier such as name, address, email, or telephone number. We do not collect PII through Client websites via our Technology.
180byTwo collects only Non-Personally Identifiable Information (“Non-PII”) from the web pages where our Clients deploy our Products. When we refer to Non-PII in this policy, we mean information that does not use a commonly recognized identifier such as name, address, email, or telephone number to identify a particular person. Non-PII includes, but is not limited to, the Internet Protocol (IP) address that your device used to connect to the internet, browser type (for example Internet Explorer or Mozilla), operating system (for example Windows or Macintosh), the URL of Client website pages or sections that you visit, the data you copied or shared, etc. Keep in mind that in certain contexts and jurisdictions, some information that we in this policy regard as Non-PII, such as IP addresses, may be regarded as “personal data” under data protection legislation in the European Union and elsewhere. We do not, however, record IP addresses for visitors to Client websites from EU countries.
The following example information is collected and used by 180byTwo to provide its Services:
180byTwo collects information on your online browsing activity to determine what types of activities and products you may be interested in and how you interact with certain content and advertisements. This information includes:
Inferred behavioral data
Websites and content viewed
Mobile applications used
Date and time of visits to a website
Search terms used on a website
Frequency of visits to a website
Engagement with an advertisement
These can be used to identify your device and typically include:
Mobile advertising identifiers (Apple IDFA and Google AAID)
Non-personal data inferred from an IP address, such as non-precise geo-location data
Clients and partners may provide 180byTwo with proprietary IDs, which are IDs that identify a customer or consumer to the client or partner. These client and partner IDs may correspond to personal information of the client or partner but 180byTwo does not see the personal information connected with these IDs.
180byTwo may use personal information that has been de-identified, typically by using a mathematical process (commonly known as a hash function) to convert information into a code. We use that de-identified data to provide our services (including to connect your activity and interests). We may provide the hashing service to our clients. In such instances, we will delete or destroy the original, personal information after the hashing process has been completed, retaining only the de-identified data. We do not use the non-hashed personal information for any purpose other than to create the hashed version of the data on behalf of our client.
180byTwo analyzes the information it collects and receives, and organizes it into user groups and audiences, based on factors such as age, gender, geography, interests and online actions. Our clients and partners then use the 180byTwo created user groups and audiences, along with information about the possible relationships among different browsers and devices, to design and deliver customized advertising campaigns or other relevant content to users on their computers, phones, and other mobile devices. Clients have the ability to combine this Third Party Data with their own First Party Data when using 180byTwo’s Product and Marketing Technology Services. Our clients and partners may also analyze and organize the underlying data to create custom user groups and audiences.
180bytwo uses the information it collects and receives to:
Identify relationships between different browsers and devices
Analyze the effectiveness of online advertising campaigns
Provide aggregated information about user interests
Attribute user interests to browsers and devices
Test the accuracy of certain products, including cross-device matching
Determine the overlap in First Party and Third Party data sets
Create pre-packaged audience segments
180byTwo clients generally use First Party Data, along with Third Party Data provided by 180byTwo, to:
Deliver targeted advertising campaigns to users across devices
Serve targeted content to users across devices
Improve the effectiveness of online advertising campaigns
Create data-driven marketing products, including models
At the request of clients, 180byTwo also shares First and Third Party Data with other companies that are responsible for the actual display and targeting of online advertising – including demand side platforms, advertising networks, advertising exchanges, and social media networks.
180bytwo does not create or share audience segments through its Online Advertising Products and Services that are classified by the Network Advertising Initiative (“NAI”) as Sensitive Information (as defined in the NAI Code of Conduct ). To learn about the non-sensitive health-related segments we offer through our Online Advertising Products and Services, click here.
180byTwo does not generate audience segments that are targeted to children younger than the age of 13.
180byTwo collects First and Third Party Data online via the use of 180byTwo pixel tags, cookies and other technologies. These allow 180byTwo to collect information from websites that 180byTwo does not own or operate. 180byTwo provides you with the ability to opt-out of the collection and use of your information for interest-based advertising via all of 180byTwo’s Services. This means that 180byTwo, and any clients that utilize data collected by 180byTwo using a 180byTwo pixel tag or similar technologies, will not have the right to use your data for online interest-based advertising purposes. 180byTwo and its clients may still collect and use data for other purposes, including analytics and research. Additionally, you will still receive online advertisements, but these advertisements may be less relevant to your interests.
To opt-out of the collection and use of data by 180byTwo for online interest-based advertising on your browser (including a mobile browser if third-party cookies are enabled in your browser), you an opt-out of the collection of data across unaffiliated sites over time for Interest-Based Advertising and other purposes from companies participating in the Digital Advertising Alliance Consumer Choice Page at www.aboutads.info/choices and from members of the Network Advertising Initiative via www.networkadvertising.org/choices .
To opt-out of the collection and use of data for interest-based advertising on your mobile device, you can modify the settings on your mobile device. For example:
For Apple Devices: Go to Settings, Select Privacy, Select Advertising, and enable the “Limit Ad Tracking” setting.
For Android Devices: Open the Google Settings App, Select Ads, and enable the “Opt out of interest-based advertising” setting.
The specific opt-out instructions for each device may differ slightly depending on which version of the operating software you are running.
Alternately, you may wish to download the TrustE mobile application here and/or the Digital Advertising Alliance “App Choices” mobile application here and follow the instructions provided.You may opt-out of the collection and use of data by all companies that offer a mobile application opt-out via the TrustE or AppChoices app. Your opt-out choice is applied only to the collection of data from applications on the device from which you opt-out.
Even after you opt-out of the use of your information by 180byTwo for Interest-Based Advertising, 180byTwo may continue to collect and use such information for other purposes, including analytics and research. Should you elect to opt-out, you will still receive ads, but these ads may be less relevant to your interests.
Also, after choosing to opt-out via any of the methods above, if you use a different device or a different browser, or if you delete browser cookies, you may need to repeat the opt-out steps for that particular device or browser. In addition, if you block cookies on your browser or if third-party cookies are blocked by default, some of the opt-out tools above may not function.
For those in Europe, you can opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.eu.
Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. If 180byTwo receives a “Do Not Track” signal from any browser other than Internet Explorer, 180bytwo will implement an opt-out. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
180byTwo also receives First Party Data from clients and partners of 180byTwo’s Products and Marketing Technology Services that is not collected directly by 180bytwo through the use of pixel tags and similar technologies. If 180byTwo receives data from a client or partner, then 180byTwo does not have the ability to offer an opt-out for the collection and use of this information by such clients and partners. You will need to visit the individual privacy statements of the sites and apps that you visit to review the their privacy policies and data collection practices.
The information that we collect from you and about you may be transferred to and stored in a country other than your country of residence, such as the USA, which may not offer the same level of protection of personal information as your country of residence. However, we will take contractual and/or other measures to ensure your personal data is protected.
In addition to the above, we adhere to the principles of the EU-US Privacy Shield and the US-Swiss Safe Harbor Principles.
When we process any personal information originating from the European Union (EU) in the USA, 180 by Two, LLC. has certified its compliance with the EU-US Privacy Shield Framework asset forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from EU member countries. 180 by Two, LLC. has certified that for all personal information it receives from the EU, it will adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access, and Recourse, Enforcement and Liability.
To find out more about the Privacy Shield, access the Privacy Shield List, and find details of our certification, please visit: https://www.privacyshield.gov/list.
Under the Privacy Shield, 180 by Two, LLC. may remain liable if its third-party service providers process your personal information 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.
Residents of the EU who believe that their personal information has not been processed in compliance with the Privacy Shield Principles may raise their complaint in the following ways:
You can contact 180 by Two, LLC. directly using the details in the “Contact Us” section below. We will respond to your complaint within 45 days of receipt.
We have further committed to refer unresolved privacy complaints under the Privacy Shield via the Better Business Bureau, an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint directly with the BBB.
Further, your complaint can be made or referred to the U.S. Department of Commerce or the Federal Trade Commission for further investigation.
For residual disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The Federal Trade Commission has investigation and enforcement authority over our compliance with the Privacy Shield.
In respect of personal information originating from Switzerland, 180 by Two, LLC. has certified its compliance with the US-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce. This means that for all personal information originating from Switzerland, 180bytwo will adhere to the Swiss Safe Harbor Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement when processing the Personal Data in the USA. To learn more about the Swiss Safe Harbor program and to view our certification page, please visit: https://safeharbor.export.gov/swisslist.aspx.
180bytwo has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.auto.bbb.org/EU-Safe-Harbor-Complaint-Form for more information and to file a complaint.
If you are from the European Union or Switzerland and would like to gain access to, or request amendment, correction or deletion of information that 180 by Two, LLC. holds about you, please contact us using the details in the “Contact Us” section below. We will consider and respond to your request in accordance with, as applicable, the Privacy Shield or US-Swiss Safe Harbor Principles, and any applicable laws.
180bytwo acknowledges the individual’s right to access their personal data and will provide you access to the personal information we hold about you to the extent it is reasonably available and allow you to correct, amend, or delete inaccurate information, as required and permitted by applicable law. If you’d like us to correct, amend, or delete any other personal information that you have provided to us, please send your request to us at firstname.lastname@example.org and we will respond to your request within 30 days.
You may request that we cease sending you any marketing communications (including by email and SMS) at any time by notifying us in writing using the contact details provided below or following any “unsubscribe” instructions included in any marketing communications which we send to you.
180byTwo has implemented processes to ensure compliance with this Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with the NAI Code of Conduct. We encourage interested persons to raise any concerns by emailing email@example.com and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.
To address any issues regarding our compliance with the NAI Code of Conduct, 180byTwo, along with the NAI and other NAI members have created a compliance program that incorporates attestation reviews, a consumer complaint process, sanctions, and annual reporting to help ensure that member companies keep their promises to you and abide by the NAI Code of Conduct. Please refer to the NAI site for more information.
In addition to sharing certain data as directed by clients, we may share information that is non-personal or de-identified with other clients and third party companies such as advertisers, agencies, ad networks or exchanges, to provide services to our clients and to enable our clients and those third parties to analyze user behaviors or to customize the ads that you see online. In addition, we may provide access to information we collect to service providers, but to the extent we have any personal information we only share personal information with service providers who will only utilize the information to provide their services to us.
If our company is sold, assigned, transferred, merged, files for bankruptcy protection, sells all or a portion of its assets, or undergoes some other change to its corporate form, information may be transferred as part of that transaction or change, including in connection with a due diligence process. We may also release information in order to comply with requests from law enforcement, government agencies, and similar entities, or to otherwise protect 180bytwo, our clients and users.
180byTwo retains the non-personal user data we collect for all of our products and services for purposes of interest-based advertising for up to thirteen (13) months from the date of its collection
180byTwo has implemented security measures which are reasonably designed to help protect the data that 180byTwo collects or receives in connection with its Services from unauthorized access, disclosure, or modification. However, no transmission or storage of data can be guaranteed to be completely secure and we therefore cannot ensure or warrant the security of any information we collect or store.
To contact us with any questions, comments, or suggestions, please email us at firstname.lastname@example.org or write to us at 180 by Two, LLC, 107 S. West Street, Suite 543, Alexandria, VA 22314 Attention: Legal Department.
A cookie is a small file of information that is stored on your hard drive when you visit a website using a particular browser. Cookies are used to store and receive information about a user’s activities on a particular website.
A pixel tag is an invisible image or block of code that allows a website owner or third party to “drop” cookies and collect certain information about a user’s activities on a particular website.
An IP address is a series of numbers that can be used to identify a particular device on a computer network. An IP address provides a general location of a device, but not a specific street address.
Advertising identifiers are unique identification numbers assigned to your mobile device by the hardware manufacturer. IDFA is the advertising identifier for Apple devices and AAID is the advertising identifier for Android devices. Advertising identifiers are used to identify devices and collect certain information about a user’s activities on a mobile device.
A hashed email address is an email address that has been transformed into a string of numbers and letters such that it cannot be traced back to the email address. There are several hashing formats. But, for example, email@example.com, when hashed might look like this: b5b2fc6f4cef.
If you have any questions about this Policy, please contact us as follows.By email at firstname.lastname@example.org or by post to 180 by Two, LLC. Attn: Legal Dept, 107 S. West Street, Suite 543, Alexandria, VA 22314