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Current as of July 16, 2013

This Privacy Policy covers and describes how Trueffect (“We”) collects, uses and disclosure of information we collect through our website www.trueffect.com and the Trueffect XLS Tool. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Trueffect. Consumer privacy is central to Trueffect. Our relationship with our customers and their audiences depends on trust in our demonstrated ability to manage information responsibly, securely and with integrity. This trust is built on three principles:

  • Disclosure: We reveal all information we manage and the ways in which it is collected and stored
  • Consent: We do not engage in sensitive targeting or data practices without express permission
  • Control: Users govern their information and the ways in which it is used

Trueffect systems and practices are built around these principles from the ground up, reflecting our commitment to practices that provide customers and consumers with the value and confidence necessary to build long-term relationships.Trueffect systems and practices are built around these principles from the ground up, reflecting our commitment to practices that provide customers and consumers with the value and confidence necessary to build long-term relationships.

Trueffect has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s Program Requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at [email protected] If you are not satisfied with our response you can contact the Feedback and Resolution System of TRUSTe here.

Validate TRUSTe privacy certification

The TRUSTe program covers our collection, use and disclosure of information we collect through our website, www.trueffect.com and our Platform. The TRUSTe program does not cover information that may be collected through downloadable software. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Trueffect.

Trueffect complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Trueffect has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Trueffect’s certification, please visit http://www.export.gov/safeharbor/.

Internet “Cookies”

Cookies are small amounts of data that a website offers to your browser in order to remember your preferences, identification, shopping cart entries, etc. from one request to the next. These may be persistent cookies that your browser stores for days or weeks, or temporary, session, cookies that a site uses to store “shopping cart” and other governing visitors’ use of the site. Cookies may be delivered by the web page, via a visible image or content frame on a page, or using small strings of invisible code placed into the web page for this purpose, and known as web beacons, clear GIFs, or pixel tags. Your browser is built to only return cookie information to the same website (domain) that issued it. Our partners, affiliates, tracking utility company, service providers use cookies to make it easier for you to navigate our site, etc. The use of cookies by our partners, affiliates, tracking utility company, service providers is not covered by our privacy policy. We do not have access or control over these cookies.

Transparency: Trueffect Advertising Technology

Trueffect serves primarily as the technology behind high-volume interactive advertising. Our customers use our platform to serve numerous “banner” ad campaigns across many online properties each day. Our platform collects or gives advertisers reporting and targeting access to the following types of data:

  • Geographic Segments: Country, State, ZIP Code, etc. (inferred using IP address)
  • Technographic Segments: Operating System, Browser Version, Domain, etc.
  • Circumstantial Segments: Time of Day, Web Page, Keyword Search Terms, etc.

Details within a cookie that has been previously issued by an advertiser may also reveal an existing relationship between the visitor and the advertiser, which the advertiser may use to reengage the consumer with appropriate messaging rather than random ads.

Cookies and Online Ad Serving

We use the data that we collect using cookies for the following purposes:

    • To better understand overall web surfing behavior and trends
    • To anonymously assess the numbers of unique visitors encountered
    • To prevent excessive display of the same ads to any single visitor
    • To refine ad targeting and drive more relevant advertising when appropriate
    • For reporting purposes

Sensitive Data and Personally-Identifiable and Information

Except for the specific business-to-business marketing activities indicated under Privacy and This Website, we do not gather or manage personally-identifiable information, collect or process inbound leads or store other personally-identifiable information. Children’s data, financial account numbers, Social Security numbers and data related to visitor health-related conditions or medical records are all inappropriate for ad targeting and not used by Trueffect. We rigorously educate our customers on these principles and require their compliance as well.

Data Accountability

Trueffect implements reasonable security measures to protect both personal and non-personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Our employees are made aware of and are accountable for compliance with these procedures.

Data Security: Processing and Retention

Trueffect performs long-term trending and analysis for our customers, and may retain ad transaction data for this purpose, including anonymous identifiers and IP address information, for up to eighteen months. This archival data is not used for online behavioral advertising or ad targeting, and is programmatically deleted within 31 days of concluding its eighteen-month lifespan.

Consumer Control: Cookies and Opt-Out

Each Trueffect client has a standard set of opt-out controls that can prevent interest-based targeting of ads:

Activating either of these mechanisms will set a persistent cookie on your browser that instructs systems not to gather data or to influence ads that you see. This opt-out cookie must remain in place to identify your preference, and targeted advertising may resume if it is deleted (such by clearing all cookies, etc.).

Privacy on This Website (Trueffect.com)

This website (Trueffect.com) serves primarily as our interface with our market and customers, and we use it to showcase best practices in privacy and data security:

Collection and Use of Personal Information

Unlike our advertising platform, site visitors may voluntarily provide personal information in certain areas on this website as well as at industry events, trade shows or other forums. The personal information we collect is used only for the purpose for which it is requested:

 

Information Sharing or Disclosure

We do not sell or share your information. We may use the services of external technology vendors to collect or fulfill requests for information or other services on our behalf, in which event personal information may come to reside on servers belonging to our authorized partners, but these third parties are required to implement similar security measures and to process your information only as authorized by Trueffect to fulfill the service(s) that they have been contracted to provide.

We may also disclose your personal information as required by law such as to comply with a subpoena, or similar legal process. If Trueffect is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. To any other third party with your prior consent to do so.

Collection and Use of Non-personal Information

If you arrived at our website by clicking a banner ad, a search link, or an email campaign for our products or services, a cookie or web beacon may be used to identify the advertisement you viewed and judge the effectiveness of our advertising campaigns. The Trueffect website may also use cookie information to better understand how the website is used, resolve technical issues, or to enhance your site experience. Persistent cookies may be used to anonymously identify your interest in our products and services on subsequent visits to our site or in network advertising where appropriate. Session cookies may also be issued while navigating different pages of our site.

Blogs
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at[email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

 Widgets
Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the “Share This” button that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Customer Testimonials
We post customer testimonials on our web site, which may contain personally identifiable information.  We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. To request removal of your personal information from Testimonials please contact us at [email protected].

Email an Article

If you choose to use our referral service to email an article to a friend, we will ask you for your friend’s email address.  We will automatically send your friend a one-time email inviting him or her to visit the site.  Trueffect stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at http://www.trueffect.com/ to request that we remove this information from our database.

Privacy on AdLegend.com

Some of our advertising customers choose to host advertising on ad.adlegend.com, which Trueffect owns and maintains for this purpose. They follow the same privacy rules and practices as any other TruEffect customer. Please visit http://ad.adlegend.com/TE_optout.html for more information or to opt out of all data collection and targeting across the entire AdLegend.com domain.

 Security
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at [email protected].

Links to Other Web Sites
Our Site includes links to other Web sites whose privacy practices may differ from those of Trueffect. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Privacy and First-Party Ad Serving

The majority of our customers deploy our technology within their own domain, allowing them serve ads within the terms and conditions of their existing privacy policies and practices. Unlike other technologies, TruEffect’s patented first-party ad serving allows them to do this without revealing either personal or non-personal data to any third party.

Our customers use their own cookies for this purpose, and must adhere to Trueffect privacy policies and industry best practices. Because of the inherent privacy and security of first-party ad serving, it can only be managed by the advertiser with whom you have a relationship. All of our first-party ad serving clients maintain their own privacy policies and govern the necessary opt-out mechanisms for their own secure, closed advertising networks.

Material Changes to this Privacy Policy

While this privacy policy will always be clearly posted, up-to-date, and compliant with current best practices, we may amend it from time to time as standards and practices within the industry evolve, or as we add new products and services, or update our product offerings. Consumers are notified before any changes to PII management or opt-in programs are implemented.

If all or part of the company is sold, merged or otherwise transferred to another entity, previously volunteered customer and prospect information may be transferred as well, along with the conditions and requirements under which it was originally collected and managed.

For more information about Trueffect’s commitment to consumer privacy, please contact [email protected] or:

Trueffect, Inc.
10170 Church Ranch Way
Suite 300
Westminster, Colorado 80021
Tel: 303.438.9597
Toll Free: 877.878.2383
Fax: 303.469.9510

Information Related to Data Collected through the Trueffect XLS Tool
Trueffect collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.

Choice
We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.

Service Provider, Sub-Processors/Onward Transfer
Trueffect may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients

Access to Data Controlled by our Clients
Trueffect has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Trueffect’s Client (the data controller). If the Client requests Trueffect to remove the data, we will respond to their request within 30 business days.

Data Retention
Trueffect will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Trueffect will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.