Last Updated: July 27th, 2018
FieldTest provides our advertiser clients with the ability to easily create and purchase targeted advertising campaigns. Our advertising products and services were designed to protect the privacy of our advertiser clients and the consumers who are served ads through the service. We believe that privacy is a right, and that you have a right to keep it private. Our goal is to be transparent about how we collect and use information about you, to keep such information secure, and to provide you with meaningful choices.
WHAT THIS POLICY COVERS
● What information we collect and why we collect it.
● How we use that information.
● The choices we offer, including how to access and update information about you.
TABLE OF CONTENTS
FieldTest, Inc. (“FieldTest”, “we”, “our”, or “us”) is a Delaware corporation located in the United States of America. On the Website, we provide information about our advertising products and services that enable brands, agencies, and retailers to leverage targeting advertising to place their message in front of consumers using programmatic display advertising (“Service”).
The Service is designed to display the ads of our clients to consumers who are likely to find those ads interesting. Our goal is to make advertising more relevant and useful to consumers by showing them ads that are based on their specific interests. These ads are displayed on websites and applications which rely on advertising revenue to support the free content we consume every day.
The Website is hosted in the United States, and is not directed to individuals under the age of sixteen (16). FieldTest does not knowingly collect information from individuals under sixteen (16) years of age without prior parental consent or consistent with applicable law.
CROSS BORDER DATA TRANSFERS
TRANSPARENCY AND CHOICE
People have different privacy concerns. We believe you should have tools to control information about you and manage your experience with us. For example, with respect to any ads that may be served on the Website, you may opt out of interest-based or targeted advertising at http://www.adsrvr.org/ and/or https://www.salesforce.com/products/marketing-cloud/sfmc/salesforce-dmp-consumer-choice. Please note that if you opt out of receiving interest-based or targeted advertising, you will continue to see the same number of ads, but they will be generic and may not be as relevant or useful to you.
You can also learn more about interest-based or targeted advertising and ad serving companies and opt-out capabilities at the Network Advertising Initiative Website, Digital Advertising Alliance Website, Digital Advertising Alliance of Canada, TrustArc, and European Interactive Advertising Digital Alliance. Please note that these opt-outs operate by placing an opt-out cookie on your device that is unique to the browser and device you used to opt-out. They may not function properly if you configured your browser to reject certain cookies. If you change browsers or computers, or delete the cookies on your computer, you will need to opt-out again. You also may be able to set your browser to notify you when a cookie is being set and to block most cookies. Your mobile device may give you the ability to opt-out of interest-based advertising (“Limit Ad Tracking” on iOS devices or “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices).
INFORMATION WE COLLECT
We collect information to better provide you information about our advertising products and services. When you interact with the Website, we may collect and combine information, including:
Information you give us. We collect the information that you voluntarily give us. For example, we ask for your contact details (such as your name, email address and phone number) when you submit a question to us; subscribe to our marketing communications, and/or request access to demo our products or services. The information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide such information. We will also let you know whether the provision of the information is required, or may be provided voluntarily and the consequences, if any, of not providing such information.
Information from your use of the Website. We collect information about how you interact with the Website and/or marketing emails such as the pages accessed, search keywords, and links clicked. This information also includes:
Device and browser information: such as your IP address, and information about the device to which an ad was served such as an anonymous device identifier, device type, software version, browser used, and settings;
Location information: such as information that allows us to periodically determine your location. For iOS consumers, you should be able to adjust the settings on your iOS device to prevent collection of location information by disabling the location services feature on your device. For Android consumers, you should be able to adjust your settings on your Android device to prevent collection of location information by disabling Bluetooth and location service features on your device.
Ad Data: such as data about the ads served through the Website, for example, how many times an ad has been served to you, where or on which page the ad was served, whether you clicked on or otherwise interacted with the ad, and attributing any actions or purchases to an ad.
We do not collect any “sensitive” or “special categories of personal data” as defined under European data protection laws.
HOW WE COLLECT INFORMATION
Web beacon; tags; pixels: are blocks of code that can read and place cookies, recognize certain types of information on your device, and your browsing behavior, as well as support Website analytics; and
SDKs or Software Development Kits: are blocks of code similar to web beacons, tags, and pixels that are embedded into an application that allow us to analyze certain information relating to your install, activation, and use of applications.
HOW WE USE THE INFORMATION COLLECTED
We may use the information collected for a variety of business purposes, such as to better understand the consumers who use and interact with the Website, how they got to our Website, and what content on the Website is of interest to them. In addition, we may use the information collected as follows:
To provide you the requested information and/or promotional materials about FieldTest and/or to carry out other purposes that are disclosed to you, and to which you consent.
To let you know about updates to our products and services;
To maintain, enhance, customize and improve the Website, and tailor the Website to your needs;
To deliver personalized ads so they are relevant to you;
To limit or cap the ads served, making sure you don’t see the same ad too many times;
To sequence ads, making sure a series of ads are served in the correct order;
To measure and report on advertising campaign performance, such as whether you clicked on an ad, went to the advertiser’s website after the ad was served, attributing actions or purchases to an ad, and/or transaction reporting and verification;
To provide data analytics, identify usage trends, and determine the effectiveness of our marketing and to the Website;
To protect the safety and security of consumers who use the Website, including acting in urgent circumstances;
To protect or defend the legal rights or property of FieldTest, consumers, our advertiser clients, and third parties, including business partners such as advertising-related companies, as well as our corporate affiliates, in connection with the Website;
To investigate, deter, and report against fraudulent, invalid, unauthorized, malicious, or illegal activity, and/or risk management; and
To comply with applicable law, rules, regulations, or legal process.
SHARING THE INFORMATION COLLECTED
We may share the information collected as follows:
Advertisers: We may share information collected with our advertiser clients and third parties, including business partners such as advertising-related companies who are obligated to comply with applicable laws concerning usage of the information, as well as our corporate affiliates, in connection with the Website (such third parties and affiliates collectively, “Affiliates”). In addition, our Affiliates may share this information with their own third-party business partners who may use the information either for themselves or on behalf of the applicable Affiliate, each only for the purposes set forth in the section above headed “How We Use Information Collected”
Service providers: We may share information collected with our service providers to facilitate some aspects of the Website or perform functions on our behalf. These service providers may use information about you solely for the purpose of providing these services to us or on our behalf;
Legal and other purposes: We may share information collected with law enforcement, regulatory authorities, courts with competent jurisdiction, emergency services, or other necessary third parties for legal, protection, security, and safety purposes; and
Business transfers: We may share information collected in connection with the sale or transfer of all or a part of our business or assets to a third party buyer.
INFORMATION OUR VENDORS AND OTHER THIRD PARTIES COLLECT
Analytics Service Providers
We may allow certain third party analytics service providers to collect the anonymous data received from cookies, web beacons, tag, pixels, and devices on our behalf, and to retain and use this data themselves. We may also share portions of our log file data, including IP addresses, with these service providers for analytics purposes.
LEGAL BASIS FOR PROCESSING INFORMATION (EEA residents only)
If you a resident located in the European Economic Area (“EEA”), our legal basis for collecting and using the information described above depends on the type of information concerned, and the specific context in which we collect it.
We may rely on our legitimate interest to collect information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to collect and process information about you, they include the interests described in the section above headed “How We Use the Information Collected”.
However, in some cases, we may rely on your consent or have a legal obligation to collect the information about you, or may otherwise need the information to protect your and/or our vital interests or those of another person or entity. If we rely on your consent to collect and/or process information about you, we will obtain such consent in compliance with applicable laws.
If you have questions about or want further information concerning the legal basis on which we collect and use information about you, please contact us using the details in the “Contact Information” section below.
EUROPEAN DATA SUBJECT RIGHTS
As a resident of a country in the EEA, you have the right to: (i) request access to and obtain a copy of the information we collect about you; (ii) request rectification or erasure; (iii) restrict the processing of such information; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of such information.
If you would like to exercise any of these rights, please contact us using the details in the “Contact Information” section below. Please note that because most of the information we collect and maintain about you can only identify a particular browser or device, and cannot identify you individually, you may need to provide us with additional information to enable us to identify the information we have about you and ensure that we accurately fulfill your request. Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested information in all situations. For example, we may not be able to provide the information requested if it imposes an undue burden or expense, requires us to release confidential commercial information, or requires the disclosure of information relating to another person.
Finally, as a resident of the EEA, you have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority. For contact details of your relevant local Data Protection Authority, please review the information located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
DELETING INFORMATION (non-EEA residents)
Our goal is to delete the information collected about you within 30 days of receiving your written request. Please note that because most of the information collected can only identify a particular browser or device, and cannot identify you individually, you may need to provide us with additional information to enable us to identify the information we have about you and ensure that we accurately fulfill your request. Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested information in all situations. For example, we may not be able to delete the information requested if it imposes an undue burden or expense, requires us to release confidential commercial information, or requires the disclosure of information relating to another person.
However, as permitted by applicable law, we retain and may use information about you as necessary to comply with our legal and/or financial obligations, resolve disputes, enforce our agreements, and other legitimate purposes (including, for document retention and security purposes). Please contact us using the details in the “Contact Information” section below to request changes or modification of the information you previously provided to us, or request deletion of other information collected about you.
DO NOT TRACK
Do Not Track (“DNT”) is a privacy preference that you can set in your browser that requests that websites and technology companies not collect certain browsing data. Currently, the standards regarding DNT and appropriate responses are not well defined. As such, FieldTest does not currently honor DNT settings in your browser.
FieldTest uses industry-standard physical, electronic, and procedural measures designed to safeguard the information in our possession against loss, theft and unauthorized use, disclosure, or modification. However, please note no transmission of information via the Internet or electronic storage solution can be guaranteed to be completely secure, although we take reasonable precautions to protect against security incidents.
RETENTION OF INFORMATION
We store information we collect about you where we have an ongoing legitimate business purpose to do so (such as to provide you with requested information, or to comply with applicable legal, tax or accounting requirements). For example, if you request information on the Website about our products and services, we will retain the data you provide for as long as we think you may have an interest in receiving information from us. Similarly, we retain log files for as long as it is necessary for our legitimate business purposes.
When we no longer have an ongoing legitimate business purpose to use the information collected, we will either delete, anonymize, or aggregate it, or if not commercially reasonable (for example, because such information has been stored in our backup archives), we will securely store the information and isolate it from any further use until deletion is possible.
The cookies set via the Website expire no later than 366 days after they were last accessed, while certain cookies that are not used for tracking purposes may be refreshed for as long as such cookies are necessary for our legitimate business purposes. We typically store the information we collect, such as IP address and other information described in the section above headed “Information We Collect” for up to 90 days before that data is anonymized and aggregated into summary reports. When we no longer need the information we collect, it is deleted from either the cookies or our servers (as applicable).
In some cases, we may keep some information for longer periods of time where required under certain laws or to comply with law enforcement or regulatory requests, which for example may include, those relating to corporate governance, taxation, money laundering, and financial reporting legislation.
EMAIL OPT OUT
You may opt-out of receiving promotional communications from us, by clicking on the “unsubscribe” link in the emails you receive from us, or by contacting us using the details in the “Contact Information” section below to have your contact information removed from our promotional email list.
Residents outside of the European Economic Area:
Attn: Privacy Officer
2118 Wilshire Blvd., #275
Santa Monica, CA 90403
European Economic Area residents:
Attn: Data Protection Officer
2118 Wilshire Blvd., #275
Santa Monica, CA 90403
Important note: The data controller of information about European Economic area residents is FieldTest, Inc. at the above address.