Xaxis is firmly committed to protecting the privacy of Internet users and fostering user confidence in the Internet, Internet advertising and direct marketing. Accordingly, we are committed to observing applicable industry guidelines including those established by the Interactive Advertising Bureau. Further, Xaxis supports deployment of the Advertising Option icon (Ad Choices), in partnership with Evidon, as part of its compliance with the Digital Advertising Alliance self-regulation program. We continually evaluate innovative ways to protect online user privacy while also seeking to deliver relevant advertising and custom online experiences on behalf of our clients. Xaxis provides services for its clients such as media planning and buying, marketing communications planning, campaign analytics and research, paid search placement and search engine optimization (“Services”).
For information on how we collect and use information that is collected directly on this website (as opposed to through the Services), please see the section entitled “Your Correspondence on this Website.”
Information We Collect Through our Services
We do not collect personally identifiable information ("PII") from users online through advertisements we manage on behalf of our clients. PII generally refers to identifying information such as an individual’s name, mailing address, phone number or e-mail address
Non-Personal Information Collected by our Services
We do collect non-personally identifiable information (“Non-PII”) to identify computers that we have interacted with before. For instance, by using Non-PII, we may be able to identify a computer that has previously seen an advertisement we launched on behalf of a client. In the context of Non-PII, whenever we refer to ‘you’ or ‘yours,’ please remember that we may be referring to a computer and not an identifiable person since we generally do not know who is using a computer at any particular time.
Through the collection and use of Non-PII, we offer a range of Services to allow advertisers to show you the most useful and relevant online advertisements across numerous websites and to prevent excessive or repeated deliveries of the same advertisements. For example, if we think that a user is interested in apparel options, then our Services may help our clients deliver interest-based online advertisements to you about a particular type of apparel. You can learn more about such advertising practices by visiting www.iab.net/privacymatters and www.aboutads.info.
We may collect Non-PII regarding your web browsing, usage or interactions with advertisements we manage on behalf of our clients. We do this to better customize the sort of advertisements you see on various websites and for other purposes such as research and analysis. Non-PII may include information such as the type of Internet browser used by an online user, the type of computer operating system used, the computer’s Internet protocol (“IP”) address, the domain name of the websites visited before and after viewing an advertisement, as well as information related to websites and web pages a user is viewing when an advertisement is shown.
We fully support the digital advertising industry’s efforts to increase transparency in the area of interest-based advertising and health segments. For more information on consumer interest segments that we may use for general health targeted advertising, please click here.
Please note – in some countries an IP address is considered PII by applicable law. If we conduct business in such countries and we know that you are located in such a country, we will treat your IP address as PII.
In such countries we interpose a “black box” which is operated by an independent third party and which separates the user’s IP address from other data we collect. If your browser does not accept cookies or if the opt-out-cookie is set, no tracking takes place.
24/7 Open AdStream LT is a service we use which places a cookie on your computer for the purpose of interest-based marketing as described above. This service, primarily used Europe, was certified with the TÜV Trusted IT Data Privacy Certification Seal on January 24, 2013. You may opt-out of the 24/7 Open AdStream LT cookie by following the instructions in the section titled, “User Choice”.
Disclosure of Information to Third Parties
We may disclose Non-PII collected through our Services, and information derived from it, to our clients and vendors. This Non-PII may be used by our clients to deliver tailored ads to users on participating websites and for other purposes as described above. This information does not include any PII that can be used to contact or identify any person individually. Further, we encourage our clients, as applicable, to use any Non-PII they receive in compliance with applicable laws and regulations and to publish privacy policies that tell you about how the information they are gathering is being used. We urge you to always read the privacy policies of the websites you visit to understand issues relating to your online privacy.
We may disclose a user’s Non-PII to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person. In addition, and if permitted by applicable law, we may also disclose and provide access to a user’s PII and Non-PII to our vendors and contractors who are performing services on our behalf. However, such vendors and contractors are not permitted to use such user information for any purpose other than providing services to us.
We use technology managed by our partners and vendors in the performance of our Services which may include cookies. We believe that the use of these tools enables us and our advertiser clients to provide users with a more meaningful web experience.
At all times, you may adjust your computer’s web browser settings to refuse all cookies. However, by doing so, you may not be able to use certain features on the websites you visit or take full advantage of all the website offerings and interest-based advertising. You can remove cookies by following directions provided in your Internet browser's "help" file.
To opt-out of interest-based advertising as provided by Xaxis and various providers, and to make educated choices accordingly, United States visitors can go to the Network Advertising Initiative and Digital Advertising Alliance, and European and Australian visitors can go to Your Online Choices.
You may also simply opt out of receiving customized advertisements we manage on behalf of our clients. Of course, doing this means that you would no longer receive customized advertisements delivered by Xaxis. To opt-out of our interest based advertising, click here:
We are sensitive to the issue of children's privacy. Therefore, our website and Services are neither developed for, nor directed at, children. If you believe your child has provided us with PII, and you would like to have the information removed, please contact us at firstname.lastname@example.org.
Linking to Other Websites
A link from our own website to another website does not imply our endorsement of that website. We do not control the websites to which we link and assume no responsibility for their content or privacy policies. Therefore, you should carefully review the privacy policies that apply to any websites you access from our website.
Transfer of Data upon Change of Control
In the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, asset purchase, or other transaction, we reserve the right to transfer all information (including any PII a user may have provided through the “contact us” page) that is in our possession or under our control to such acquiring party.
Data Storage - United States, United Kingdom & Germany
A Special Note about the European Union
The company complies with the U.S.-EU 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 information from European Union member countries and Switzerland. The company 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 the company’s certification, please visit http://www.export.gov/safeharbor/
Xaxis has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Xaxis, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
If you have questions or concerns regarding this statement, you should contact us through email or by mail. You can address your general questions and comments by e-mail to email@example.com or by mail: Xaxis, LLC, 132 West 31 Street, 11th Floor, New York, NY 10001, Attn: Legal Department.
March 1, 2013