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Overview

Privacy at Conversant

We believe in providing you with transparency around how we collect, use and share the personal data we collect from you. The following privacy statements are tailored for the different ways your personal data may be collected by Conversant LLC, or any of its subsidiaries, including Commission Junction LLC, a Conversant Company (“Conversant,” “we,” “us,” or “our”).

· The Services Privacy Policy addresses personal data we may collect and use through our services (“Services”), including how we collect and use pseudonymous data to enable personalized advertising.

· The Website Privacy Policy addresses what data we may collect and use on our websites and from our clients.

· The Recruiting Privacy Policy addresses information we may collect in connection with Conversant’s employment recruiting efforts.

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CONVERSANT PRIVACY POLICY for Services

CONVERSANT EUROPE LTD. PRIVACY POLICY for Services

Last Modified: July 8, 2019

INTRODUCTION:

Welcome to the Conversant Privacy Policy (“Privacy Policy”). By visiting our Privacy Policy, you’ve taken the first step in educating yourself about advertising businesses such as ours which contribute to the Internet’s ability to remain largely a diverse ecosystem of free content, as well as to provide a better digital browsing experience.

WHAT DOES CONVERSANT DO?

Conversant Europe Ltd (“Conversant”, “we”, “us”) provides online advertising services through its two main lines of business – Conversant and CJ Affiliate. In performing these services, we follow two beliefs:

· First – data protection is essential to the growth and prosperity of the Internet.

· Second – a personalised web experience can provide significant benefits to Internet users if done properly.

In accordance with these beliefs, Conversant creates results for advertisers and publishers in revolutionary ways without compromising individual privacy or data protection. 

If you have questions or concerns regarding this statement, please contact us by clicking here.

DEFINITIONS USED IN THIS PRIVACY POLICY:

To start, it is important for you to know a few definitions that are key to understanding our services and privacy practices:

Personal Data” is information relating to an identified or identifiable person.  In other words, if the data singles out one person, it is considered Personal Data. 

Identifiable Personal Data” is information that directly identifies a person.  This type of data includes things like full name, home address, telephone number, or email address.

Pseudonymous Personal Data” is information that cannot be attributed to a specific person without the use of additional information, and where any such additional information is kept separately and is subject to technical and organisational measures to ensure that the Pseudonymous Personal Data are not attributed to an identified or identifiable person.  In other words, this data singles out one person but does not directly identity that person.  This type of data includes online identifiers, such as Cookie IDs (see below for more information about cookies), which allow companies like Conversant to recognise a unique person without knowing or intending to learn the actual identity of that person.

Anonymous Data” is information which does not relate to an identified or identifiable person.  In other words, this is data which does not enable a person to be identified or "singled out".  This type of data includes aggregate statistics about a group of people [as well as online data elements such as browser types, operating systems, domain names and referring website addresses, so long as the data elements combined do not enable the individual to be identified].

Cookies” are files that are stored on your web-enabled device and are used to improve your experience when seeing web and mobile advertisements. We use cookies to estimate the total reach of an advertising campaign, as well as frequency of display, and to serve advertisements which are relevant to you. This allows advertisers to determine with greater accuracy the composition of the audience they reach and attempt to reach an audience that is interested in their products or services. There are many misconceptions about cookies. Cookies cannot erase your hard drive, install programs, or automatically collect Identifiable Personal Data from your browser or device.

“Local Storage Data” are similar to cookies in that they allow data to be persisted in your browser when you visit a website. Local storage data are used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.  Information set in local storage data are only accessible from the same website domain that set the local storage data, and can only be set or accessed using JavaScript on pages from that same website. Local storage data have many of the same restrictions as cookies – if you delete cookies or your internet cache, local storage data are also deleted. Similarly, if you block cookies then local storage data are also blocked.  Since local storage data are so similar to cookies and we treat local storage data with the same privacy and data protection principles as cookies, when we use the term “cookies” on this page or any other material on our website or elsewhere, we are including both cookies and local storage data. 

Device IDs” are unique identifiers associated with your mobile device to be used for advertising. These identifiers are assigned by your mobile device operating system, such as Apple’s iOS and Google’s Play Services for Android, and do not reveal Identifiable Personal Data. Device IDs can be reset in your mobile device settings. 

Log files” track actions occurring on Sites and collect data including, as an example, your IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, click data and types of advertisements viewed.

"Web beacons" are objects that are embedded in a web page or e-mail and are usually invisible to the user but are used to track a web user’s navigation of a website or collection of websites or pages, interaction with an e-mail, use of mobile applications, the completion of transactions, submittal of applications and browsing behaviour.

Location Data” means a user’s location while they are on their device which is utilised by Conversant to deliver advertisements. As with all data Conversant collects, this is limited to non-precise location data (as defined by the Network Advertising Initiative’s current definition of imprecise location data) unless the user has consented to allow their precise location to be used for interest-based advertising.

“Interest-based Advertising” or “IBA” means the collection of data across web domains owned or operated by different entities for the purpose of delivering advertising based on preferences or interests known or inferred from the data collected.

Please take some time to read about what our business does, learn how we ensure that data you share with us is collected and used safely, and visit resources that provide more depth on our industry.

Short Form Privacy Policy

Scope

What Conversant Does

Information Collection & Use

Self-Regulation

Your Choices

For Clients and Publishers

Contact Us

Modifications to this Privacy Policy

SHORT FORM PRIVACY POLICY

We have included a table summarising our practices solely for your convenience and reference purposes. This table is not an exhaustive description of our privacy practices and should not be construed to define, limit, and/or describe the scope or extent of this Privacy Policy. As a result, we urge you to read the entire Privacy Policy:

Information Collection: Identifiable Personal Data

We do not collect Identifiable Personal Data except unless you voluntarily provide it to us. For example, Identifiable Personal Data may be collected should a user contact Conversant on his/her own initiative.

Information Collection:  Pseudonymous Personal Data

The Pseudonymous Personal Data we collect includes Cookie IDs and Device IDs.  These online identifiers allow us to recognise individuals as unique when we collect data or serve them an ad.  We may associate transactions and browsing behaviour with these online identifiers in order to make the ads more relevant to them.  We additionally collect IP Addresses for analytics and general location-based advertising and analytics, but we do not use IP Address as an online identifier.

Information Collection: Anonymous Data

The Anonymous Data we collect includes browser types, operating systems, domain names, platform type, language preference, access dates and times, referring website addresses, and we may additionally take Pseudonymous Personal Data and aggregate it to make it anonymous (i.e., 40% of website visitors were women).

How Information is Used

We use the data we collect to serve you with relevant content and ads when you visit websites and mobile apps.  We additionally ensure that websites and apps get paid for their content when they are the reason that you visited an advertiser’s website or app.  For example, if you read a blog about a pair of shoes and later visited a website to view or purchase that pair of shoes, we would ensure that the blog gets compensated.

Sharing Your Information

We do not sell the information that we collect.  However, we may share your information with our clients and third parties to enable us to serve ads and for measurement purposes so that they can track our performance and properly compensate websites and mobile apps for the content.  Our clients are forbidden from using this data for any other purpose.  We may additionally share data with our subsidiaries and affiliates as necessary to provide services to our clients.

Your Choices

You can opt out of receiving relevant online advertising served by Conversant by clicking here.  Please note that you may still receive advertisements from Conversant, but they will not be relevant to your interests.  In addition, you may view and delete data we have collected about you by clicking here.  You may also have other rights under applicable data protection laws, which are explained in our long form Privacy Policy.

Security

We use reasonable and appropriate technical and organisational security measures to protect your data.

Retention

Conversant and CJ Affiliate have different data retention policies. Conversant retains non-transactional Pseudonymous Personal Data we collect or receive online for no more than eighteen (18) months for advertising purposes. Conversant may additionally retain Pseudonymous Personal Data we receive offline and transactional data we collect online for advertising purposes for up to six (6) years, and in no event will this data include a transaction that occurred over nine (9) years ago.

CJ Affiliate, which ensure websites and mobile apps get compensated for their content, retains Pseudonymous Personal Data we collect or receive online for up to six (6) years.  Anonymous Data for reporting and analytics may be retained for a longer period.

Changes

We may change this Privacy Policy at any time by posting the revised Privacy Policy on the Site along with the date such Privacy Policy was last updated.  Where we are required by applicable data protection laws to seek your consent to any material changes, we will do so.

Contact Us

If you have any questions about this Privacy Policy, or the practices discussed herein, please contact us by clicking here.

Controller

Conversant Europe Ltd. is the controller of the data we collect through  our online advertising services. 

Data Protection Officer

Our Data Protection Officer is Fieldfisher LLP (Riverbank House, 2 Swan Lane, London, EC4R 3TT).  You may email our Data Protection officer at DPOfficer AT conversantmedia.com, but we respectfully request that you only email our Data Protection Officer regarding urgent matters.  Otherwise, for all other inquiries, please click on the contact form.

SCOPE

This Privacy Policy is primarily intended to provide a description of the ways in which we collect and use information to deliver and measure advertising and content across the Internet. For more on how we handle information collected from clients and publishers or visitors to our websites, please see “Website Privacy Policy.”

Please be aware that in addition to our Sites, the websites of our clients and publishers, applications on which we place advertisements, and any third party websites linked to one of our Sites, may also collect information from you for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you. Such information collected by such websites and mobile applications and their affiliated or third party partners may include Pseudonymous Personal Data through the use of cookies and other technologies. It may also include any Personal Data you choose to provide in registering and transacting with such websites and mobile applications. Although we choose our business partners and clients carefully, Conversant is not responsible for the privacy practices of websites and mobile applications operated by such third parties. You should check the applicable privacy policies of such websites and mobile applications you visit to determine how they handle any information they collect from you.

WHAT CONVERSANT DOES

While you visit certain websites and mobile applications, there are other companies working behind the scenes to help provide you with a great digital experience. These third party companies provide vital services such as analytics, advertising and fraud prevention for retailers, publishers, and other organisations. These services enable these third party companies to, among other things, provide the advertising that keeps your favorite blogs free, your favorite stores in business, and your advertising experience more relevant.

We help companies provide digital advertising, both in browsers and mobile applications, and we do it in a variety of ways, from banner ads to coupon codes. To make some of these things possible, we need to utilise information to provide smarter decision making. Technologies such as cookies and mobile device IDs enable companies like ours to provide more relevant advertising while keeping your identity unknown to Conversant.

In addition to our advertising services, we also utilise our technology to provide life-saving messages during tornadoes and AMBER Alerts, geotargeted to individuals in affected areas. To learn more about these internationally-recognised programs established by Conversant through an organisation called the Federation for Internet Alerts, click here.

INFORMATION COLLECTION AND USE

Information Collected by Conversant

Conversant only collects Pseudonymous Personal Data from you (unless you provide other Identifiable Personal Data voluntarily through our Sites) and may collect this in a variety of ways. We use technologies such as cookies, log files, pixel tags or other similar technologies to collect Pseudonymous Personal Data about the browser or device you are using, including browsing activity, online transactions, and IP addresses. We may also receive Pseudonymous Personal Data from third parties.

Some of our clients provide Identifiable Personal Data such as your name, address, email address and associated transactional information directly to a third party, our affiliated company, Alliance Data FHC (trading as Epsilon International), with whom Conversant has a contractual relationship. This third party removes the Identifiable Personal Data and provides Conversant only the Pseudonymous Personal Data for our use in providing advertising to you. All Pseudonymous Personal Data received and collected by Conversant from the various sources may be combined and used to provide you advertising, properly compensate websites and mobile apps for their content, and for other analytical purposes.

Conversant's Legitimate Interests

We (and our clients) have a legitimate interest in conducting this data processing and have taken necessary measures to minimise any data protection impacts to you.  In particular:

· We have taken appropriate measures to ensure that we do not collect or receive any user Identifiable Personal Data in our advertising activities (unless they have provided it voluntarily and consented). 

· We have a third party audit our technology every year to verify that our preventative measures are functioning correctly. 

· We additionally do not collect data or serve advertisement pertaining to sensitive subjects, such as health or financial eligibility. 

· We have a robust data protection and security team which ensures that we are not only legally compliant, but that we are also respecting your privacy and properly implementing our Privacy by Design business model. 

· Furthermore, we are strong believers in the principle of data minimsation and as indicated in this privacy policy, we only collect the data that we need and only retain it as long as necessary. 

· Even though we do not hold Identifiable Personal Data, our security team ensures that appropriate security measures are implemented from start to finish of data processing. 

· We know that even with the above safeguards in place, you may still be uncomfortable with our data processing, which is why we allow you to opt out of Interest-Based Advertising and further allow you to review and delete data which pertains to you.

Conversant's Use of Data

The Pseudonymous Personal Data we collect is used for marketing purposes, enables us to determine which advertisements perform well, allows us to more effectively match ads, mobile application and website content to your interests, assists us in improving the operation of our services, helps us ensure that Sites and mobile applications get compensated for their content, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding use of Conversant’s services.

When a user responds to or views an Internet advertisement served by Conversant (such as through third-party websites), we may assign a pseudonymous online identifier to the end user's Internet browser or device, often via a cookie. These technologies provide Conversant with information needed for the purpose of paying third-parties affiliate commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser's website. If the Internet user re-visits the advertiser's site directly, Conversant is able to track the user's activities on the advertiser's site (for example, whether they make a purchase) and credit the third-party website that referred the user.  In other words, if you read a blog about a pair of shoes and decides to visit that advertiser’s website and purchase that pair of shoes, we would ensure that the blog gets compensated for referring you to that advertiser’s website.

We also may use cookies and similar technologies, to track a user's behaviour across multiple devices.  This helps us to develop a predictive profile of the end user's interests across these different devices for the purpose of sending them relevant advertisements on multiple browsers and devices and prevent us from sending the same advertisement too often. This is called cross-device IBA. We may also use this cross-device functionality for the purpose of more accurately paying third-parties affiliate commissions, as described in the paragraph directly above.

To opt out of Conversant IBA, please follow the opt-out instructions below in the “Your Choices” and “Mobile Device Choices” sections of our Privacy Policy. Upon opt-out, we will no longer collect behavioural data on your browser and will also no longer send behavioural data to other browsers or devices associated with you. However, data that was collected on your browser or device prior to you opting out may still impact the advertisements you see on other browsers and devices associated with you if you have not also opted out on those browsers and devices. To opt out of interest-based advertising on all browsers and devices, you will need to follow the instructions below for each browser and device.

We may also conduct surveys by serving interactive ads that ask you to provide information such as your gender and age range, which information may be associated with a device ID or a cookie ID. If you decide to respond, your demographic information will also be associated with a device ID or cookie ID and used only for the purposes described in this Privacy Policy.

Information Sharing by Conversant

Conversant will only share your information for limited purposes such as those provided in this Privacy Policy. This includes sharing information (1) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (2) to enforce our terms of use and other agreements or to protect our rights; (3) to protect the safety of members of the public and users of the service; (4) with Conversant affiliates, partners and clients for marketing purposes; (5) with vendors, administrative service providers, technology providers, and carefully selected partners for services including, but not limited to, data validation, enhancement, information verification and suppression services; or (6) for any other purpose for which you provide consent. None of this information will include Identifiable Personal Data unless you have provided this to us voluntarily.

While Conversant strongly encourages clients and partners to adopt responsible approaches to online marketing, and conducts due diligence on its partners, Conversant is not responsible for the information practices of such clients and partners. With respect to IBA, Conversant and other third parties may use Pseudonymous Personal Data collected or shared with respect to your visits to websites with whom we have relationships for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you.

In the event that Conversant is acquired by or merged with a third party, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganisation, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your information is treated, transferred, or used.

Lead Generation

Conversant provides lead generation services to clients where we work with website and mobile app publishers who utilise their media channels to generate user interest or inquiry into advertiser products and services.  For example, a client may be interested in contacting you to promote their service and product and request the you fill out an online form. Through this process in which Conversant facilitates the exchange of user information (typically Identifiable Personal Data held by a website in accordance with their Privacy Policy) from website publishers to advertisers, Conversant does not ever receive the Identifiable Personal Data.

Instead, through these online forms hosted by our clients, or third parties acting on the behalf of us or our clients, advertisers or publishers may collect Identifiable Personal Data that a user has voluntarily provided. This information may be used for the same purposes listed in “Information Sharing by Conversant,” above. This information may also be used to verify any information submitted to us or any of our clients, and for any suppression or opt-out purposes.

Conversant still does receive Pseudonymous Personal Data through these services and may serve advertisements to you based on information you submitted to our clients during the website registration process with them.

International data transfers

Conversant, its group companies, partners and service providers may transfer data to, and process data in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective.

Specifically, Conversant's servers are located in in the United States and Amsterdam, and our group companies and third party service providers and partners operate around the world.  This means that when we collect data, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Policy. These measures include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect Personal Data they process from the EEA in accordance with European Union data protection law. 

Our Standard Contractual Clauses can be provided on request.  We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

Security

The security of your information is important to us. We have implemented appropriate technical and organisational security measures to protect the information in our care, both during transmission and once we receive it. We take physical and technical security measures to protect our data from accidental or unlawful destruction, loss, or alteration, and from unauthorised disclosure or access.

No transmission of data over the Internet is guaranteed to be completely secure. While we strive to protect your data, it may be possible for third parties not under the control of Conversant to unlawfully intercept or access transmissions or private communications. Unauthorised entry or use, hardware or software failure, and other factors may compromise data security. Conversant cannot ensure or warrant the security of information you transmit to us. You acknowledge and assume this risk when communicating with Conversant.

Retention

Conversant and CJ Affiliate have different data retention policies. Conversant retains non-transactional Pseudonymous Personal Data we collect or receive online for no more than eighteen (18) months for advertising purposes. Conversant may additionally retain Pseudonymous Personal Data we receive offline and transactional data we collect online for advertising purposes for up to six (6) years, and in no event will this data include a transaction that occurred over nine (9) years ago. As mentioned above, this offline data is provided to us by our clients and pertain to transactions you have made with them. 

CJ Affiliate, which ensure websites and mobile apps get compensated for their content, retains Pseudonymous Personal Data we collect or receive online for up to six (6) years.  Anonymous Data for reporting and analytics may be retained for a longer period.

CONSENT MANAGEMENT TOOL

We also offer a consent management tool for publishers and advertisers built on the IAB Europe Transparency & Consent Framework that helps website operators provide consumers with information and choices about data. When you visit a site or app that uses this tool, we may use tags, cookies, SDKs, and plug-ins to store information about privacy notices that you have received and privacy choices that you have made. We do this pursuant to the IAB Europe Transparency & Consent Framework’s policies and technical specifications. We do not use information collected from this tool for other purposes.

SELF-REGULATION

Our industry has a rigorous voluntary self-regulatory regime, and we are active members of industry groups such as the Network Advertising Initiative (NAI), Interactive Advertising Bureau (IAB), Interactive Advertising Bureau Europe (IAB EU), Interactive Advertising Bureau UK (IAB UK), Digital Advertising Alliance (DAA), European Digital Advertising Alliance (EDAA) and Digital Advertising Alliance of Canada (DAAC), who promulgate codes of conduct to which their members must adhere. These codes impose requirements on participating companies such as transparency and choice around the use of data for IBA and some require regular audits of member privacy practices.

Conversant is an active member of these and other groups, and where Conversant engages in activities regulated by these programs, we comply with the NAI Codes of Conduct. We also support the DAA Self-Regulatory Principles, the EDAA Self-Regulatory Principles, and the DAAC Self-Regulatory Principles.

YOUR CHOICES

We hope that after reading through this Privacy Policy that you feel comfortable we are collecting and using data responsibly, and that the cumulative benefits of our work are valuable to the Internet as a whole and your individual browsing experience. As part of our commitment to user privacy, we give user the ability to opt out of IBA provided by Conversant. If you would like to opt out of IBA, please click here to learn more and opt out.

You will need to make this selection on each browser or device on which you do not want to receive IBA from Conversant. If you or your privacy software deletes the opt-out cookies from your computer, you will need to repeat the process.

As an alternative, you may also visit the Network Advertising Initiative opt-out page at: www.networkadvertising.org/choices or the European Digital Advertising Alliance opt-out page at:  http://youronlinechoices.com/.

Mobile Device Choices

For mobile websites, you can follow the opt-out instructions provided above.

To learn how to opt out receiving relevant advertisements on mobile applications, please visit this page: http://www.networkadvertising.org/mobile-choices

Data Subject Requests

We understand that you may be interested about what data we hold about you and which advertising interest segments we believe pertain to you.  We are pleased to present you with an opportunity to view this data and even delete it if you choose to do so by clicking here.

If you wish to exercise another data protection right to which you are entitled under applicable data protection laws (including rights of correction, restriction, portability or to object to data processing), please contact us using the contact details provided below.

Device Access Consent Choices

We will only access your device if you have provided us with unambiguous consent, except as indicated in the below paragraph.  This includes reading or writing cookies directly from your device.  You may have provided us with consent through a prominent notice on this website or one of our partner’s websites.  You can review and change your choices at any time by clicking on the link at the top of the page.

However, even if you have not provided consent, we may need to access your device as necessary to ensure that websites and mobile applications can provide you with loyalty points or cash back.  If you have requested loyalty points or cash back from one of our partners, then we need to access your device to create a cookie ID or read a device ID so that we can ensure that they provide loyalty points or cash back to the correct person.  In other words, in these situations, accessing your device is strictly necessary to provide you with the services that you are requesting, and thus we must access your device even without your consent.  In these situations where we do not have consent, we limit our device access and data processing to only what is necessary to provide you with the services that you are requesting.

FOR CLIENTS AND PUBLISHERS

The Conversant network includes our clients and publishers involved in advertising campaign transactions. Information collected from clients and publishers includes Identifiable Personal Data that is necessary to conduct our business, such as name, phone number, and email address. Payments made to and from Conversant require the collection of Identifiable Personal Data that may include credit card numbers and bank account information. Phone numbers may be used for sales or inventory acquisition purposes.

This information is collected, modified and stored in a password protected environment and is used for purposes including service, media delivery, contact, billing and accounts payable. We will not sell or rent this information to non-Conversant entities. All client and publisher information collected for these purposes is explicit, voluntary, manually entered, and can be opted-out.  We process this information with consent or as necessary for our legitimate interests to operate our business.

Security:

See “Security” under Information Collection and Use, above.

Information Sharing:

This client and publisher information is not shared with any third party outside Conversant and its affiliated companies, except for that necessary to conduct business, such as clearing a credit card transaction for an advertising campaign purchase or making an ACH direct deposit to pay a publisher, or as required by law. The security of this information is crucial to our success in the highly competitive field of online advertising. Conversant may, from time to time, use "gallery" pages to identify clients or publishers by business identity ONLY (e.g. Adcycle.com is a new Publisher in the Conversant Network).

Log Files:

We record the IP address of new clients and publishers at sign-up. This can assist in administering the Site and client or publisher accounts, including features designed to enhance the Client experience. This information is part of the secure member database and is password protected.

Our Communications:

We send all new clients and publishers a welcoming email to verify password and user name, and may communicate with you about program or other information at the contact information you provide. We may also email individuals that have provided us with their contact info so that we can communicate information about Conversant’s services, in accordance with those individuals' communication preferences. You can request to opt out of these emails by filling out this form.

Site and Service Updates:

We may send Site and service announcement updates by email. Because these announcements contain important information about services, it is not possible to unsubscribe. We also communicate with clients and publishers to provide requested services and in regards to issues relating to their account via email or phone.

Correction/Updating Contact Info:

If a client’s or publisher’s contact info changes (such as email address) or they would like their contact info removed from our system, we provide several ways to correct or update this info. The following options are provided:

Make the changes online by entering the member area.

Fill out a form by clicking here

Contact your account manager.

All requests to remove a client or publisher from our system will be verified prior to removal to ensure the proper identity of the requester.

CONTACT INFORMATION

Conversant Europe Ltd. is the controller of the data we process.  Have a question on something not addressed or have a complaint? Please use the Feedback form located here.

Our Data Protection Officer Fieldfisher LLP (Riverbank House, 2 Swan Lane, London, EC4R 3TT) is tasked with ensuring our data protection program is operating effectively and in accordance with law.  If you need to contact our Data Protection Officer, you may email DPOfficer AT conversantmedia.com.  However, we respectfully request that you only email our Data Protection Officer regarding urgent matters.  Otherwise, for all other inquiries, please click on the contact form.

As an EU resident, you have a right to report a concern to your country’s Data Protection Authority.  For example, UK residents can report a concern to the United Kingdom Data Protection Authority at this website - https://ico.org.uk/concerns/.  However, we respectfully request that you contact us first so that we can assist you.

MODIFICATIONS TO THIS PRIVACY POLICY

We may occasionally make changes to this Privacy Policy. If we do, we will update the “Last Modified” date above. If we make a material change, such as the ways in which we use Personal Data, we will notify you via a prominent notice on our Site and, if required by data protection law, seek your consent.

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Website Privacy Policy

Effective as of 13 September 2018.

This privacy policy applies solely to information collected on our corporate websites, such a, and other affiliate sites that display or link directly to this policy (collectively, “Sites”). Please read this policy before using, or submitting information to, these Sites.

This privacy policy is designed to help ensure that visitors to our Sites understand what data is collected on our Sites and how this data is used or disclosed. This privacy policy also applies only to information collected on our Sites.

This privacy policy does not apply to data collected through our Services. For more information about our privacy policy for our Services, please visit our Services Privacy Policy.

This privacy policy also does not apply to personal collected during our recruiting process. For more information about our data protection practices for recruiting purposes, please visit Recruiting Privacy Policy.

Controller

Conversant Europe Ltd. is the controller of the data we collect from our Sites.  If you have a question on something not addressed or have a complaint? Please use the Feedback form located here.

WHAT INFORMATION DO WE Collect/RECEIVE?

We may collect, store and use the information you voluntarily provide to us through our Sites.

1. For instance, we may collect your contact information if you provide it to us through the “contact us” form, or through other forms available on our Sites. These registration forms may ask for such information as your name, the company you work for, business title, postal address, email address, telephone number and other information. You must be 18 years of age or older to submit this registration information to our Sites.

2. In addition, if you choose to correspond with us through email, we may retain the content of your email messages together with your email address and the resulting correspondence with you.

3. You may also disclose certain information about yourself on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information, and may be available to visitors to our Sites and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, on our Sites.

Further, our servers may automatically collect certain information from your browser when you visit our Sites. This information may include the type of web browser you are using and its version, your IP address and the pages you visited on our Sites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and to improve marketing, analytics or site functionality.

We may also collect your information when you attend one of our marketing events. Finally, we may receive your information from partners who have collected information you have posted publicly.

To exercise your choice around receiving marketing email or other direct marketing from us, see the Data Subject Rights Process below.

HOW DO WE COLLECT DATA?

Outside of you providing us with your contact information as outlined above, we, or our service providers, may also collect information about your browser or device through various technologies, some of which are outlined below.

Cookies

Cookies are small text files that store data using your web browser to make your browsing experience easier and faster. We, and our third-party service providers who assist with managing our Sites, may use cookies and similar technologies on our Sites. We use performance and functionality cookies, as described below, to improve the performance of our Sites and to make our Sites more user-friendly.

The European Union Directive 2009/136/EC, amending Directive 2002/58/EC on Privacy and Electronic Communications (otherwise known as the e-Privacy or Cookie Directive), and laws in EU countries implementing such directive, require user consent before a site may place cookies and other similar technologies on your browser.

Types of Cookies used on our Sites


Performance cookies: These cookies collect information about how visitors use our Sites for web analytics purposes. For instance, we may use cookies to analyze which pages visitors go to most often and if they receive any error messages. These cookies are used to help improve our Sites and your experience on our Sites. By using our Sites, you agree that we can place these types of cookies on your browser. If you do not wish to accept cookies in connection with your use of this Web site, you must stop using our site.

Functionality cookies:
These cookies allow our Sites to remember choices you make (such as remembering your username and password, language preference or the region you are in) and provide enhanced, more personalized features. These cookies may also be used to remember changes you have made to text size, fonts and other personalization’s. They may also be used to provide services you have requested, such as keeping you logged in to your account as you browse the internet. These cookies do not collect information about your browsing activity on other websites. By using our Sites, or by signing up for an account with us, you agree that we can place these types of cookies on your browser. If you do not wish to accept cookies in connection with your use of this Web site, you must stop using our site.

Other tracking technologies
We, and our service providers, may use other technologies, such as beacons, tags and scripts, on our Sites for analytics and administrative purposes. These technologies may be used in analyzing trends, administering the Site, recording users’ movements around the Site and gathering demographic information about our visitor base as a whole. We may receive reports based on the use of these technologies by these companies on an aggregated basis.

We may partner with third parties who provide certain features on our Sites, or to display advertising, based upon your web browsing activity using local storage objects (LSOs) such as Flash to collect and store information. Various browsers may offer their own management tools for removing Flash LSOs. To manage Flash LSOs, please click here.

If you have a question on something not addressed or have a complaint? Please use the Feedback form located here. You may also reach our Data Protection officer DPOfficer AT conversantmedia.com.

HOW DO WE USE THE INFORMATION WE COLLECT? Lawful basis

We may use the information you provided to us in the forms on our Sites or through email correspondence with us to market to you per the preferences you specified when you registered on our Sites. Our marketing efforts include business-to-business direct marketing and promotional information related to our marketing services.  We collect this information through a consent mechanism available when you provide us with your information.

We may also use the information we collect to fulfill requests you have made to us, such as to communicate with you, respond to your inquiries and provide newsletters or updates. We may use the information to inform you of service and product updates, white papers, new products, market research opportunities and other related information from us. We rely on legitimate interests as a lawful basis of processing for the purpose of operating our business, obtaining new clients, retaining existing customers and responding to your questions/inquiries.

We may use the information we automatically collect from your browser to analyze trends, administer our Sites, note users’ activities on our Sites, help us understand the parts of our Sites visited most often and gather broad demographic information for aggregate use in improving our Sites.  We, and our digital partners, rely on consent to drop the cookies and legitimate interests to process the information we collect thereafter. We rely on legitimate interests as a lawful basis of processing for the purpose of operating our business, obtaining new clients, retaining existing customers and responding to your questions/inquiries.

Interest-Based Advertising or Cross-App Advertising
As you browse the internet or go across mobile apps, you may see advertisements on the web pages or the apps you visit. Some of these ads may be more relevant to you based on a variety of factors, such as the previous websites or apps you have visited, your perceived interests and your demographic information. This practice is called Interest-Based Advertising. To learn more about this practice, please visit the Interactive Advertising Bureau EU.

We may work with our advertising partners to enable the delivery of relevant messages to the right consumers while protecting consumer privacy and offering choices about participating in such activities. Our third-party partners may use technologies, such as cookies, to gather information about your activities on this Site and other sites in order to provide you with relevant advertising. Relevant advertising does not result in more ads, but rather the relevancy of the ads you see.

If you have a question on something not addressed or have a complaint? Please use the Feedback form located here. You may also reach our Data Protection officer DPOfficer AT conversantmedia.com.

WHO DO WE SHARE YOUR DATA WITH?

We may share or disclose the information we collect or receive through this Site:

  • With our affiliate companies, including Alliance Data FHC, Inc. (trading as Epsilon International), Epsilon Data Management, LLC or CJ Affiliate by Conversant, who may be able to address or respond to your inquiries.
  • With our service providers who perform services on our behalf, including our email service providers, our customer data base provider and analytics providers.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

LINKS TO THIRD-PARTY SITES

Our Sites contain links to unaffiliated third-party sites. We do not endorse or make any representations about any third-party sites (or any information, software or other products or materials found there) to which our sites might link. This privacy policy does not apply to the information collection and use practices of third-party sites. We encourage you to review the privacy policies of these unaffiliated third-party sites to understand their data collection and use practices.

CONTENT SHARING FEATURES

Our sites include social media sharing features, such as LinkedIn, Google+, Facebook and Twitter buttons. It may set a cookie to enable the feature to function properly. These features may collect your IP address and which page you are visiting on our Sites. Social media features are governed by that social media company’s privacy policy.

We also give users the option to share our stories about us on social networks such as Facebook, LinkedIn and Twitter.

We may also allow you to email useful information from our Sites to a friend or colleague. If you choose to do so, we may ask you to provide your full name and email address, as well as your friend’s complete email address. We will send your friend a one-time email inviting him or her to visit the site, except where prohibited by law. Your friend or colleague may contact us via email Marketing_requests AT conversantmedia.com or via the Feedback form located here to opt-out.

Data Transfer

We may transfer your personal information from your country of residence to the United States, Canada and/or India.  We rely on standard contractual clauses if we do transfer your data to such countries.

Data Subject Rights

1.  By writing our Data Protection officer, DPOfficer AT conversantmedia.com, you may:

· request access to and rectification or erasure of your personal data; or

· request restriction of processing concerning your personal data; or

· object to processing of your personal data; or

· request a copy of your personal data you have provided to us be transferred to another organization (as outlined under the right to data portability).

2.  If we have relied on consent to obtain your personal information, such as on our registration page, then you have the right to withdraw consent at any time. You may either unsubscribe from our emails or you may opt-out of our cookies (see below). You may also reach our Data Protection officer DPOfficer AT conversantmedia.com to exercise your choices.

3.  You have the right to lodge a complaint with a supervisory authority.

4.  We may process some of your personal data based on contractual requirements, such sending you transactional emails, or as a requirement necessary to enter into a contract.

CHOICES AND ACCESS

Client/prospect opt-out
We maintain contact lists to communicate with our clients and prospects. Individuals must affirmatively ask to join one or more of our email lists or postal mailing lists by registering on our Sites and/or through one of our conferences. All email messages sent to these lists include an opportunity to unsubscribe or opt out of future email messages via a hyperlink in the email.

You may request to be removed from future email messages by contacting us via the Feedback form located here or via Marketing_requests@conversantmedia.com. You may also reach our Data Protection officer DPOfficer AT conversantmedia.com.

We also maintain a postal mailing list to communicate with our clients and prospects. You can request to be removed from our mailing list by sending your name and postal address to us via the Feedback form located here or via Marketing_requests@conversantmedia.com. You may also reach our Data Protection officer DPOfficer AT conversantmedia.com.

RETENTION

Conversant retains the data it collects from its Sites and through its direct marketing efforts for a period of 4 (four) years.

PARTICIPATION IN ONLINE FORUMS

Our Sites may provide you with the opportunity to participate in various online forums. If you contribute any content to an online forum, you retain your rights to any content you post. However, by posting content on or through an online forum, you grant us a worldwide, nonexclusive, royalty-free license (with the right to sublicense) to use, copy, reproduce, process, adapt, modify, publish, transmit, display and distribute your content in any and all media or distribution methods (now known or later developed) for any and all purposes.

Any content you post to an online forum may be publically viewed and used by anyone on the internet. You are responsible for any content you post, and for any consequences thereof, including the use of your content by other users. To protect your privacy, we remind you and ask you to not submit personal information in a public forum.

By posting, you agree not to post any content that (i) is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, invasive of another’s privacy, hateful, or racially, ethnically or otherwise objectionable; (ii) you do not have a right to make available under any law or under contractual or fiduciary relationships; (iii) infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party; or (iv) contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment.

We may prescreen, refuse or remove any content that you post. We may also modify or adapt your content in order to transmit, display or distribute it.

We do not control the content posted by public users to our Sites and, as such, do not guarantee the accuracy, integrity or quality of such content. Under no circumstances will we be liable in any way for any user-contributed content, including, but not limited to, any errors or omissions in any content, or any loss or damage of any kind incurred as a result of the use of any user-contributed content.

To request removal of your personal information from our online forums, or to notify us of a posting that violates our rules for posting in Conversant’s online forums described above, please contact us via the Feedback form located here or via Marketing_requests@conversantmedia.com. If we are unable to remove your personal information, we will let you know that we are unable to do so and why.

SENSITIVE INFORMATION

We ask that you not send or disclose any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) to us through our Sites or otherwise.

USE OF THE SITES BY CHILDREN

Our Sites are not intended for children under the age of thirteen (13). We ask that children not provide personal information through our Sites. If we become aware that we have collected personal information from a child under the age of 13, we will delete that information from our records.

SECURITY

We use physical, electronic and administrative safeguards designed to protect your personal information against loss, misuse or alteration. All information is stored securely and may only be accessed by employees with a legitimate business need to access the information. No method of transmission over the internet, or method of electronic storage, is 100 percent secure, and we cannot guarantee its absolute security.

CONTACT INFORMATION

Conversant Europe Ltd. is the controller of the data we process.  If have a question on something not addressed or have a complaint? Please use the Feedback form located here or via Marketing_requests@conversantmedia.com.

Our Data Protection Officer Fieldfisher LLP (Riverbank House, 2 Swan Lane, London, EC4R 3TT) is tasked with ensuring our data protection program is operating effectively and in accordance with law.  If you need to contact our Data Protection Officer, you may email DPOfficer AT conversantmedia.com.  However, we respectfully request that you only email our Data Protection Officer regarding urgent matters.  Otherwise, for all other inquiries, please click on the contact form or email us via Marketing_requests@conversantmedia.com.As an EU resident, you have a right to report a concern to your country’s Data Protection Authority.  For example, UK residents can report a concern to the United Kingdom Data Protection Authority at this website - https://ico.org.uk/concerns/.  However, we respectfully request that you contact us first so that we can assist you.

MODIFICATIONS TO THIS PRIVACY POLICY

We may occasionally make changes to this Privacy Policy. If we do, we will update the “Last Modified” date above. If we make a material change, such as the ways in which we use Personal Data, we will notify you via a prominent notice on our Site and, if required by data protection law, seek your consent

_____________________________________________________________________________________

Careers Privacy Notice

Effective date: 25 May 2018

Please read this Careers Privacy Notice carefully. By submitting application information through this website, or by emailing our recruiters, you, the applicant, consent to Conversant Europe Ltd.’s (“Conversant”, “we”, “us”) collection and use of Applicant Data as described below.

This Careers Privacy Policy applies to personal data collected or received by Conversant Europe Ltd. and CJ Affiliate by Conversant (collectively, "Conversant" or "we") during its recruiting process.

Controller

Conversant is the controller of the personal data we collect or receive when you apply for a job.  If you have a question on something not addressed or have a complaint, please email us via Recruiting_requests AT conversantmedia.com.

Data Collected and Purpose

User Provided Data. You may voluntarily provide personal data to Conversant through Taleo, Smashfly OnGig, and third party recruiters.  Taleo, Smashfly and OnGig are recruiting software programs. You can register and create a profile, providing:

· Your name

· Your social media sign-in information (through LinkedIn, Facebook, Twitter and others)

· Your email address

· Your postal address

· Your phone number

· Your picture

· Jobs you show interest in (e.g. ones you apply for, follow, comment on, etc.)

· The date you first looked at a job

· Educational Level

· Your phone number

· Resume/CV

Data about you that we receive from you or others in connection with your application is referred to in this Privacy Notice as "Applicant Data." If Conversant considers your application or extends an offer of employment, Conversant may collect certain additional data either directly from you or from third parties such as background checks, where allowed by local law, with your consent. Conversant relies on your consent when collecting this data.

Conversant may also collect and retain Applicant Data manually or electronically (e.g., if you send us an email). Conversant relies on Legitimate Interest when collecting and using such personal data.

Applicant Data from this Site. When you visit our site, your browser automatically sends us an Internet Protocol address and certain other data, including the type of browser you use. Our cookies on this site are used solely to facilitate your online experience, and are not used to make employment-related decisions. Please visit Conversant Privacy Policy to learn more about what data we collect when you visit our Sites. 

Use of Applicant Data.

Conversant may use Applicant Data to communicate with you in writing or by telephone or online, to evaluate your application, to analyse Conversant staffing needs and practices, or otherwise to efficiently manage the Conversant hiring process and employee administration. We may combine Applicant Data with research tools and data from other sources.  Conversant collects and uses this Applicant Data for hiring purposes.

Data disclosures.

Applicant Data is controlled primarily (but not exclusively) by Conversant’s human resources department staff, and may be stored electronically or in hard copy. Other staff involved in hiring or information management also may have access to some or all Applicant Data, as may senior management, including hiring associates outside of the European Economic Area, including Canada, Hong Kong, India and United States. To achieve the objectives described above, and because we are part of a larger group of companies operating internationally, we may from time to time make Applicant Data available to other companies within the Conversant family of companies, including Alliance Data FHC, Inc. (trading as Epsilon International) and Epsilon Data Management, LLC. Also, we may from time to time make Applicant Data available to legal and regulatory authorities (such as labour and tax authorities), to our accountants, auditors, solicitors, lawyers and other outside professional advisers, and to parties providing products or services to us (such as IT systems suppliers, and human resources consultants). Notwithstanding any other provision of this Privacy Policy, Conversant also may disclose Applicant Data to any third party when disclosure is required by law, or desirable to permit us to exercise our legal rights or take action regarding illegal activities, or to protect the safety of any person. If all or part of our company is sold, merged, or otherwise transferred to another entity, we may transfer Applicant Data as part of that transaction.

Retention, transfers and security of Applicant Data.

We may store Applicant Data for as long as needed for the purposes indicated in this Privacy Statement, but in any event not longer than permitted by local law from the date of collection unless you become employed by Conversant, in which case a different retention period may apply. Records not specifically designated as Applicant Data may have different retention periods (e.g., email server records of emails received or sent). As stated above, Applicant Data are processed in and thereafter stored on local servers in the United States. Conversant has certain security measures to protect the confidentiality of Applicant Data (such as firewalls to protect servers), but the storage and communication of personal data cannot always be completely secure.

The servers for Taleo, Smashfly and Ongig are located within the United States and are participates in the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework. Conversant transfers Applicant Data to its Affiliates listed above under a standard contractual clause.

Data Subject Rights and your Choices

You may access and rectify your Applicant Data by logging into Taleo and updating your Applicant Data.

You can also contact us at please email us via Recruiting_requests AT conversantmedia.com to receive more detailed information about the data gathered about you, the categories and purposes of processing of your data and to whom your data has been transmitted. You may also withdraw your consent to or restrict our processing of your Applicant Data or by writing our Data Protection Officer via email at please email us via Recruiting_requests AT conversantmedia.com.

Minors

We do not knowingly collect application information from children under age 16.

CONTACT INFORMATION

Conversant Europe Ltd. is the controller of the data we process.  If have a question on something not addressed or have a complaint? Please email us via Recruiting_requests AT conversantmedia.com.

Our Data Protection Officer Fieldfisher LLP (Riverbank House, 2 Swan Lane, London, EC4R 3TT) is tasked with ensuring our data protection program is operating effectively and in accordance with law.  If you need to contact our Data Protection Officer, you may email DPOfficer AT conversantmedia.com.  However, we respectfully request that you only email our Data Protection Officer regarding urgent matters.  Otherwise, for all other inquiries, please email us via Recruiting_requests AT conversantmedia.com.

As an EU resident, you have a right to report a concern to your country’s Data Protection Authority.  For example, UK residents can report a concern to the United Kingdom Data Protection Authority at this website - https://ico.org.uk/concerns/.  However, we respectfully request that you please email us via Recruiting_requests AT conversantmedia.com so that we can assist you.

MODIFICATIONS TO THIS PRIVACY POLICY

We may occasionally make changes to this Privacy Policy. If we do, we will update the “Last Modified” date above. If we make a material change, such as the ways in which we use Personal Data, we will notify you via a prominent notice on our Site and, if required by data protection law, seek your consent.