1. About AdRoll Group's Services
AdRoll Group provides targeted advertising and marketing services for our advertiser clients ("Advertisers").
Our products help show our customers’ ads to the people that are most likely to find them interesting. We aim to make advertising more useful and relevant to consumers by showing ads that are best tied to their specific interests. And we show these ads on websites which rely on advertising revenue to support the content we all consume each day, often for free.
To do this, when you visit a website or a mobile application operated by an Advertiser (collectively “Digital Properties”) or we serve you an ad on behalf of an Advertiser on a third party site, we may collect some or all of the data described in this Privacy Notice. Our platform uses that data, as well as other data described below, to help Advertisers provide ads to you that are more relevant to you.
For example, let’s say you just joined a local soccer club and are in the market for a new soccer ball. If you visit ACME Soccer Ball Co.’s website in search of the perfect soccer ball, but don’t purchase one just yet because you are still looking, we may later show you ACME Soccer Ball Co. ads to encourage you to come back and purchase one of their soccer balls, perhaps even with a discount offer or notice of an upcoming sale. We may also show you ads from ACME Soccer Ball Co. or other companies with additional product recommendations you may be interested in, such as for soccer cleats, or tickets to an upcoming soccer match, as you browse the internet. If you gave ACME Soccer Ball Co. your email address for marketing purposes, we may also serve ACME Soccer Ball Co. ads to you through other channels, such as by email.
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 may disclose information about you:
With an Advertiser whose Digital Properties you have visited: We may share information about how you have interacted with that Advertiser’s Digital Properties or its Ads.
With our service providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
With service providers to our Advertisers: Our Advertisers may contract with companies who handle data (such as managing Advertisers’ customer lists) for them.
With our subsidiaries and related companies: But they will only process your data for the purposes already explained in this Privacy Notice. Our subsidiaries are AdRoll Advertising Limited (Ireland), AdRoll Holdings Limited (Ireland), AdRoll Limited (UK), AdRoll K.K. (Japan), and AdRoll Pty Limited (Australia).
In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of AdRoll Group, our Advertisers or any other third party.
To Comply with legal process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
To Investigate Wrongdoing and Protect Ourselves or Third Parties: To enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).
We also share hashed email addresses (or other pseudonymous identifiers associated with those hashes), technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other advertising companies in the digital advertising ecosystem. This enables them and us to better target ads to you.
6. Cookies and related technologies
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.
AdRoll Group is also a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing personalized ads from us and from other NAI approved member companies.
We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.
We also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt out via their Your Online Choices website.
Please note that when using the ad industry opt-out tools described above:
If you opt-out your browser may still send us data, for example your IP address. However, we isolate this data and do not use it other than for accounting and, in some cases, for fraud prevention. If you have opted-out on that browser, we do not use this data to personalize ads or to track you.
If you use multiple browsers or devices we will additionally opt out those we have linked to you. Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt out on each browser or device.
Other ad companies’ opt-outs may function differently than our opt-out.
To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:
iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
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.
In addition, if you are located in a European Territory you will also have additional data protection rights. These are described under the heading "Additional data protection rights for European Territory residents" below.
8. Data retention
We retain personal data we collect directly for targeting purposes for no more than 12 months, after which time we employ measures to delete it. However for identifiable data that we hold on behalf of an Advertiser such as their email address list, we will retain until the Advertiser asks us to delete it.
Personal data collected for other purposes 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 may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. In general, these countries will be the countries in which we, our Advertisers, or our or their service providers operate.
Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.
For example, when we transfer your information from a European Territory to our parent company in the United States, we do so under the European Commission's Standard Contractual Clauses. These Standard Contractual Clauses are incorporated in the AdRoll Data Processing Addendum here.
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:
you can object to processing of your personal information, ask us to restrict processing of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact us about questions or concerns” heading below.
If you wish to access, correct, update or request deletion of your personal information, you can contact us using the contact details provided under the “Contact us about questions or concerns” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Specifically, you can withdraw consent for us or our partners to drop our __adroll cookie and our partners’ cookies by clicking here or by withdrawing consent for AdRoll when you see a “consent banner” on a publisher or advertiser site which lists AdRoll as a vendor.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Territories are available here.) However, if you have any questions about our collection and use of your personal information, please contact us first at firstname.lastname@example.org or email@example.com. If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer at firstname.lastname@example.org.
Please note that we have no direct relationship with the individuals whose personal data we process on behalf of our clients and partners. Where we act as a processor for our clients and partners (for example, with respect to our email products), you should direct any requests to access, correct, update, or delete your personal data to the respective client or partner. We will respond to any requests by a client or partner to provide assistance with such requests within 30 days.
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. Information for California Residents Only
This section supplements the information contained in this Service Privacy Notice and applies solely to visitors, users, and others who are residents of the State of California, as defined in Section 17014 of Title 18 of the California Code of Regulations. This section is effective as of January 1, 2020, to comply with the California Consumer Privacy Act of 2018 (“CCPA”).
Any terms defined in the CCPA have the same meaning when used in this section.
Information We Collect and the Purposes for Which this Information is Used
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). This collection of information is listed in What Data We Collect.
We set out below the CCPA categories of personal information we have collected from consumers within the last twelve (12) months in respect of our Services. Please note that personal information in certain categories may overlap with other categories.
A.IdentifiersYesDevice IP address, email address, cookie string data, pseudonymous data (e.g. hashed emails), operating system, and (in the case of mobile devices) your device type, and mobile device's identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifier that may be assigned to any device by third parties and cross-referenced to recognize a device.Directly and indirectly from consumers, third party data providers and Advertising Partners. In the case of business email addresses, RollWorks B2B Services may infer a business email address.
B.Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))YesIn respect of RollWorks B2B Services:
Name, business address, business telephone number, education, employment and employment history.
In respect of AdRoll D2C Services:
The perceived general education level of consumers may be collected for D2C marketing, advertising and analytics to the extent relevant for providing marketing or advertising.Directly from third party data providers.
C.Protected classification characteristics under California or federal lawYesLimited to age ranges such as 35-44, 45-54, 55-64 and 65+ and male/female gender categories are sometimes collected for use of AdRoll’s D2C Services that do not carry a risk of unintended discrimination.From third party data providers.
D.Commercial informationYesRecords of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.Directly from consumers and Advertiser.
F.Internet or other similar network activityYesBrowsing history, search history, information on a consumer's interaction with a website, application, or advertisement. 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 B2B website, what items you placed into your online shopping cart, what products were purchased and the price of the products purchased.Directly from cookie browsing history on Advertisers’ Digital Properties.
Non-personal information about one of our ads e.g. the third party who served the ad, and the name of the ad) may be connected with browsing history or activity on our websites for the purposes of determining attribution information (e.g. whether particular ad led to a consumer visiting our website, and, if so, which particular ad campaign).
G.Geolocation dataYesNon-precise geolocation derived from IP address.Directly from consumers and Advertising Partners.
I.Professional or employment-related informationYesIn respect of RollWorks B2B business only:
Current or past job history, including details about the employer (industry, name, company location, company domain or URL), and employee (positions held, duration of employment, and office location of the company where the employee worked).Third party data providers.
J.Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R Part 99))No--
K.Inferences drawn from other personal informationYesCreating profiles that reflect consumer preferences and interests.Third party data providers.
For clarity, under CCPA personal information does not include:
Publicly available information from government records;
De-identified or aggregated consumer information; and
Information excluded from the CCPA's scope such as:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Purposes for Which Personal Information is Collected
NextRoll is a marketing and advertising technology company. All data we collect is for the business purpose of providing services primarily for our marketing, advertising or analytical Services. However, as part of performing these Services, we also use data collected (as identified above) for the following additional business purposes:
Auditing Interactions with Consumers: count ad impressions and verify the quality of ad impressions served to unique visitors identified by cookie id or other unique identifier;
Debugging and Repair: the identification and repair of impairments to intended and existing functionalities in our Services and NextRoll Technology, perform debugging and related activities to repair errors that impair the functionality of our Services;
Security: detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities;
Internal Research and Development: conduct internal research for technological development of our Services and demonstration of the performance of these Services; and
Quality and Safety Maintenance and Verification: verify the quality or safety of our Services and improve, upgrade or enhance our Services and NextRoll Technology we provide.
For more information on how we use this data, please refer to How We Use the Data We Collect.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose (as set out above) or sell your personal information, subject to your right to opt-out of those sales (See Personal Information Sales Opt-In Rights).
The Data Sharing section sets out the personal information that we share with third parties.
Disclosure of Personal Information for a Business Purpose
With the exception of our RollWorks B2B Contact Data, NextRoll’s Services do not amount to a sale of personal information. Instead, NextRoll discloses personal data for business purposes, primarily to perform its advertising, marketing and analytical Services, but also for the purposes set out as items (1), (2) and (3) in the Purposes for which Personal Information is Collected above.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for our business purposes:
Category A: Identifiers;
Category B: California Customer Records personal information categories;
Category C: Protected classification characteristics under California or federal law;
Category D: Commercial information;
Category F: Internet or other similar network activity;
Category G: Non-precise geolocation derived from IP address;
Category I: Professional or employment-related information; and
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the categories of third parties set out in Data Sharing.
Sales of Personal Information
In the preceding (12) twelve months, pursuant to our RollWorks B2B Contact Data Service, we have sold personal information in the form of business emails from Category A (Identifiers).
Other than our RollWorks B2B Contact Data Service, we do not consider that our Services constitute a ‘sale of personal information’ under the CCPA. Instead, in the course of providing our Services, we disclose personal information for business purposes.
However, we aim to provide consumers with control over the collection and use of their personal information. Consistent with this goal, we will honor requests from consumers to “opt-out” of the collection and disclosure of their personal information. Your Rights and Choices section below provides instructions on how to opt-out of our collection and disclosure of personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes the rights of California residents under CCPA and provides information on how to exercise those rights.
Right to Know and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you;
The categories of sources for the personal information we collected about you;
Our business or commercial purpose for collecting or selling that personal information;
The categories of third parties with whom we share that personal information;
The specific pieces of personal information we collected about you (otherwise known as a data portability request); and
Two separate lists where we have sold or disclosed your personal information for a business purpose:
Sales: identifying the personal information categories that each category of recipient purchased; and
Disclosures for a business purpose: identifying the personal information categories that each category of recipient obtained
Right to Delete
You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Data Portability and Right to Deletion), we will delete (and direct our services providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relations with you or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; and
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Right to Know, Data Portability and Right to Deletion
To exercise the access, data portability, and deletion rights described above, please submit verifiable consumer request to us by either:
Calling us at 1-844-740-7126; or
Visiting this webpage.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable request for access of data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
As mentioned above in Sales of Personal Information, we have elected to honor sale opt-out rights. Please see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will deliver our written response to you electronically unless you indicate delivery to be by mail.
Any disclosures we provide to you will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot complete a request, if applicable. Please note that personal information deleted during this period as set out in Data Retention will not be provided.
The format of our responses to you concerning personal information collected, disclosed or sold will be provided in a readily useable format that should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out Rights
To exercise the right to opt-out of our sale of your Contact Data or to opt out of interest-based advertising, you (or your authorized representative) may submit a request to us by visiting the Do Not Sell My Personal Information webpage.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
14. Changes to this Service Privacy Notice
We may update or modify this Service Privacy Notice at our discretion and at any time. When we make changes to this Service Privacy Notice, we will post the updated notice online and update the notice’s effective date. Please review this Service Privacy Notice periodically.
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.
15. Contact us about questions or concerns
If you have any questions about this Privacy Notice or our privacy practices, you can contact email@example.com.
If you are located in a European Territory and we are processing your data as a data controller, AdRoll Advertising Limited is the data controller of your information. To contact AdRoll Advertising Limited please email firstname.lastname@example.org or write to us at the following address:
AdRoll Advertising Limited
1, Burlington Plaza
Dublin 4, Ireland
If you wish to escalate your inquiry after contacting the support team, you are welcome to contact email@example.com or our Data Protection Officer: Lucid Privacy Group
Attn: AdRoll Data Protection Officer
Lucid Privacy Group
1556 Shrader Street
San Francisco, CA 94117