Effective Date: January 1, 2020
Xaxis is firmly committed to protecting user privacy and fostering user confidence in the Internet and digital advertising. We continually evaluate innovative ways to protect user privacy while also seeking to deliver relevant advertising and custom online experiences on behalf of our clients.
What is in this Privacy Notice?
This Privacy Notice describes the information Xaxis collects from web sites, applications, and other digital properties (we refer to all of these as “Sites”), and on the Xaxis corporate web site, www.xaxis.com (“Xaxis Web Site”). We explain how we use this information to provide “Services” to our clients. We also explain how you can manage your privacy choices and exercise your rights in relation to certain data about you that is collected and used by Xaxis.
For purposes of this Privacy Notice, “device” includes computers, smartphones, tablet computers, e-readers, connected television and/or over-the-top television devices (“OTT TV Devices”) and other digital devices capable of maintaining an Internet connection; and “mobile device” includes smartphones and tablet computers.
Who are we?
Xaxis is a business which operates globally as part of the GroupM media investment group. In the European Economic Area (“EEA”) and Switzerland, through its Xaxis EMEA division, the legal entity responsible for the data that Xaxis collects is GroupM UK Digital Ltd. Outside of the EEA and Switzerland the responsible legal entity is Xaxis, LLC. Except as expressly stated otherwise, the use of information by our non-Xaxis affiliates, our clients, our service providers, and other third parties is not covered by this Privacy Notice.
If you have any questions, including any request to exercise any of your legal rights outlined below, please see the “Contact Us” section at the bottom of this Privacy Notice.
Xaxis does not provide its advertising-related services (“Services”) directly to consumers. Instead, our clients are corporate businesses, including advertisers and agencies. Our clients include other GroupM and WPP group companies, which in turn perform advertising-related services for their own clients.
Our clients use our Services, on their own behalf and/or on behalf of their own clients, to help them understand the advertising they deliver online (e.g. what sites it was delivered on, who saw it and whether or not anyone interacted with it) and to improve the effectiveness of that advertising. We also help them to try to deliver advertising to consumers who are more likely to be interested in their products and services.
When we help clients to select audiences to deliver their advertising to, we use certain demographic information (such as age, gender, education, income and household status (e.g., number of children)), geography (but not precise location), interests, activities, and similar information (“User Information”). We call this type of advertising "Interest-Based Advertising".
For example, if we think that a user is interested in mobile phone options, then our Services may help our clients deliver Interest-Based Advertisements to that user about a particular type of mobile phone product or service, as follows:
What Categories of Information Do We Collect Through Provision of Our Services
When you view and interact with Sites and with advertisements where our Services are utilized, we do not collect data that reveals your real-world identity, such as your name, address, phone number or other non-publicly available government-issued identifiers.
Rather, our Services are designed to collect and/or use information about the type of web pages you visit and about interactions you have with Sites and with our clients’ advertisements. We also collect information that identifies the browsers and devices of users who have viewed our clients’ advertising. This information includes the following categories of data:
These can be used to identify a user’s browser, mobile advertising environment, and/or device. Technical Identifiers include:
Additional Technical Information
Online Activity Information
Xaxis collects the information explained below about your online browsing activity to determine what types of activities, services and products you and other users may be interested in and how you and other users interact with certain advertisements. This information includes:
How We Collect Information through Our Services
|Cookie||is a small alphanumeric text file that is stored in a browser by a web site or by a third-party ad server or other third party which allows that web site or third party to recognize that browser and remember User Information and other information. Xaxis utilizes third-party targeting cookies of its affiliate [m]PLATFORM, which are named “Mookie” and operate on the mookie1.com domain. Mookie cookies are persistent cookies that contain unique randomly-generated values that enable our Services to distinguish browsers and devices and are associated with User Information and other information. Mookie cookies, together with this associated information, are used in the performance of our Services, and in particular Interest-Based Advertising activities.|
|Advertising ID||is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment. It is associated with User Information and other information and, together with this associated information, is used in the performance of our Services, and in particular Interest-Based Advertising activities.|
|Pixel||is a line of code that is used by a Site or third party to assign online activities to a device or browser, or more specifically to the applicable cookie or advertising ID. The use of a pixel allows us to record, for example, that a device or browser has visited a particular Site or page.|
The following chart provides information about the Mookie cookies, all of which are “persistent” cookies (meaning they are stored until they expire or are deleted/removed by a user) mapped to the mookie1.com domain:
|Cookie Name||Cookie Behavior Capability||Information held in Cookie||Expiry from last refresh (days)|
|Targeting (client data)||Targeting and Optimization (user data)||Reporting Attribution and Security|
|id||Y||Y||Y||Unique serial number||395 days|
|ov||N||N||Y||Unique identifier||395 days|
|mdata||Y||N||N||Unique serial number, Creation timestamp, cookie version||395 days|
|syncdata_<PARTNER>||Y||N||N||Unique serial number, Creation timestamp||10 days|
Our opt-out cookies are programmed to expire ten years after they are initially issued. If you buy a new device, upgrade or change web browsers or clear your cookies (i.e. delete these opt-out cookies), you will need to perform the opt-out process again. In order for the opt-out process to work, your browser must be set to accept third-party cookies. If cookies are not enabled in your browser, including if third-party cookies are disabled, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly.
In browser environments, you may also refuse or remove cookies from both Xaxis and other service providers via the following methods:
You may also limit ad tracking in mobile and OTT TV Device app environments. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. The following information is solely for informational purposes, and we cannot guarantee that the methods below are the most current:
Additional information regarding user choice in application environments is available at www.networkadvertising.org/mobile-choices.
Network Advertising Initiative
We are a member of the Network Advertising Initiative (NAI) and adhere to the NAI Code of Conduct in those markets where these self-regulatory frameworks apply and are in effect. In accordance with the Code of Conduct, we require our Xaxis Marketplace (formerly Xaxis Publisher Network and 24/7 Access) clients to inform users about their privacy and information collection practices via their privacy policies and to include in their privacy policies information regarding the use of third-party advertising technology and services on their Sites, the types of data collected through these services, the use and distribution of that data, and a link to an industry standard opt-out from Interest-Based Advertising. We periodically monitor the Sites of our clients to determine whether they are adequately disclosing and updating their privacy statements.
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 standard interest segments based on health-related information or interests that we may use for Interest-Based Advertising purposes, please click here.
You can also click here to reach the Network Advertising Initiative site, a central location for information about Interest-Based Advertising and the choices available to you, and to opt out of receiving third-party Interest-Based Advertising via cookies from us and other NAI member companies.
Digital Advertising Alliance, European Interactive Digital Advertising Alliance, and Digital Advertising Alliance of Canada
We are a member of the Digital Advertising Alliance (DAA), the European Interactive Digital Advertising Alliance (EDAA), and the Digital Advertising Alliance of Canada (DAAC) and, in connection with these memberships, adhere to the DAA Self-Regulatory Principles, the IAB Europe EU Framework for Online Behavioural Advertising, and the DAAC’s Canadian Self-Regulatory Principles for Online Behavioural Advertising, respectively, in those markets where the applicable self-regulatory framework applies.
Xaxis supports deployment of the Advertising Option icons (AdChoices and, where available, AppChoices) as part of its participation in the DAA’s self-regulatory framework (in the United States), the IAB Europe OBA Framework for Online Behavioral Advertising (in Europe), and the DAAC’s Canadian Self-Regulatory Principles for Online Behavioural Advertising (in Canada). Advertisements that are provided by organizations that participate in these frameworks will display the icon displayed below when technologically feasible. Clicking on the icon provides you with information about Interest-Based Advertising.
You can click here to reach the DAA site, which has additional information about Interest-Based Advertising and the DAA’s self-regulatory framework, as well as a mechanism to opt out of receiving third-party Interest-Based Advertising via cookies from us and other DAA member companies.
Neither the Services nor the Xaxis Web Site is developed for, or directed at, children (as defined by applicable law) or at Sites primarily directed to children. We do not knowingly collect information from children (determined in accordance with the age requirements for the applicable country) nor do we sell the personal information of children under the age of 16 years of age. If you believe a child has provided us with personal information and you would like to have the information removed, please contact us using any of the methods set forth below in the “Contact Us” section.
Transfer of Data in the Event of Acquisition
In the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information (including any information a user may have provided through our “Contact”/“Contact Us” page on the Xaxis Web Site) that is in our possession or under our control to the acquiring party.
Information Security and Global Data Transfers
We follow generally accepted online advertising industry standards to protect against unauthorized access to, unlawful processing of, unauthorized retention of, and unauthorized disclosure of data. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure.
Xaxis Services are used globally, and therefore we may transfer data to countries around the world, including countries outside of your country. We will, where necessary, put in place appropriate safeguards to ensure this data is protected. When we transfer personal data from the EEA or Switzerland to an affiliate outside the EEA or Switzerland, we enter into standard (“model”) contractual clauses, with the recipient in order to ensure an appropriate level of data protection. When we transfer personal data from the EEA or Switzerland to an unaffiliated entity (such as a service provider performing services on our behalf) outside the EEA or Switzerland, we either enter into standard (“model”) contractual clauses, or ensure that the transfer is pursuant to another valid mechanism, such as the service provider being certified under the EU-U.S. Privacy Shield Framework.
We maintain the information we collect through our Services in non-aggregated form for a period of not more than 13 months, and we retain much of this data for shorter periods of time. This data includes domain level information, content topics, ad interactions, browser type and language settings. We maintain this information for the 13-month period to enable our clients to perform year-over-year analyses. For example, a retailer may wish to compare the effectiveness of its online advertising activities at Christmas for the current year vs. the effectiveness in the prior year. A 13-month retention period enables that client to perform such comparison.
We maintain information we collect through our Services in an aggregated form for a period longer than 13 months.
How Information is Used and Shared on the Xaxis Web Site
We respect the privacy of users of the Xaxis Web Site, and recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner with that information. This section contains important information about how we use information collected via the Xaxis Web Site and how you can manage your privacy choices and exercise your rights in relation to certain data about you that is collected via the Xaxis Web Site.
What Information Do We Collect and Use?
When you use the Xaxis Web Site, we may collect and use the following information:
If you provide us information through our “Contact”/“Contact Us” page on the Xaxis Web Site, we may keep a record of the information you provide, including your email address and any other personal information you provide, solely for the purposes of responding to your inquiry or providing you with relevant material and, where you have consented, with marketing communications about our products and services. We may disclose this personal information to third party marketing automation service providers solely for those purposes; those service providers are not permitted to use this information for any purpose other than providing services to us.
How Do We Use the Information We Collect on the Xaxis Web Site?
Xaxis uses this information in the following ways:
Do We Pass Your Information to Third Parties?
We may send your information (including your personal data) to our affiliate GroupM, service providers and other third parties (as set out in Section 1, Disclosure of Information to Third Parties) to help us process that information for the purposes set out in this Section 2. In addition, in the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, purchase, or other transaction, we reserve the right to transfer your information (including your personal data) to the acquiring party.
We also may disclose your information (including your personal data) to third parties, including law enforcement, when we reasonably believe we are required to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.
How Do We Use Your Information for Marketing?
We will only provide you with marketing information that you have requested.
Where Do We Send Your Information?
We are a global company and therefore we may transfer your information (including your personal data) to countries around the world, including countries outside of your country. We will, where necessary, put in place appropriate safeguards to ensure your information is protected. When we transfer personal data from the EEA or Switzerland to an affiliate outside the EEA or Switzerland, we enter into standard (“model”) contractual clauses with the recipient in order to ensure an appropriate level of data protection. When we transfer personal data from the EEA or Switzerland to an unaffiliated entity (such as a service provider performing services on our behalf) outside the EEA or Switzerland, we either enter into standard (“model”) contractual clauses, or ensure that the transfer is pursuant to another valid mechanism, such as the service provider being certified under the EU-U.S. Privacy Shield Framework.
How Do We Keep and Protect Your Information?
We will keep your information that we collect on the Xaxis Web Site for a reasonable period for the purposes set out above in this Section 2. We follow generally accepted online advertising industry standards to ensure that your personal data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure.
Linking to Other Sites
For information on how to opt out from, or manage, Xaxis cookies and/or cookies from both Xaxis and other service providers, please see the “Opt-Out/Right to Withdraw Consent” subsection in Section 1 above.
EEA and Switzerland
Legal Bases for Processing Information
We collect, use, share, and/or transfer personal data of individuals in the EEA and Switzerland only when we have a lawful basis for doing so, which typically entails user consent or our legitimate interests.
Where required by applicable law we only deliver Interest-Based Advertising to individuals who have provided consent for that activity.
To the extent we rely on your consent, which may be provided either directly to us or via a third party, to use your information in certain ways, we will process your personal data within the scope of that consent.
In our capacity as a data controller we intend to rely on consent as a lawful basis for all “Purposes” under the IAB Europe’s Transparency & Consent Framework other than “Measurement” (which Purpose includes measurement, analysis, and reporting with respect to the applicable personal data). In connection with such Purpose, when we process data for measuring the delivery of advertising or analyzing its effectiveness we have a legitimate interest in understanding that our suppliers have delivered the advertising that they have contracted to deliver. In addition, we believe that advertising clients have a legitimate interest in understanding whether or not their advertising is delivered and whether it is effective. We believe these activities are fundamental to online advertising but do not result in any decisions which affect individuals.
If you are in the European Union, you have the right to object to any of this processing. If you want to object, please click here.
Rights of Individuals in the EEA and Switzerland
Individuals in the EEA and Switzerland have a number of rights with regard to their personal data, including the right to access their information. For these users, in many cases where we process your personal data, you may also have a right to restrict or limit the ways in which we use that personal data.
In certain circumstances – for example, where we process your personal data for directing marketing purposes or pursuant to our legitimate interests – you also have the right to object to the processing of your personal data by us, and you can also request that we delete your personal data. You also have a right to obtain a copy of your personal data in an easily accessible format, and in certain circumstances, you may also request to transfer personal data about you to third parties. We don’t retain and store your actual browsing activity history in association with a Mookie cookie ID or a mobile advertising ID. Instead, we use an “aggregate scoring” methodology that categorizes the Sites you browse and then use combinations of these categorizations to create segments and deliver Interest-Based Advertising. As a consequence, we are unable technically to offer the ability for you to change individual elements of data that lead to the segment allocation simply because we do not retain them. If you believe that we hold or have used inaccurate personal data elements about you, please note that you have the right to withdraw your consent to our processing of your personal data at any time.
If you have questions about any of these rights, please contact us. You should also contact us if your personal data or preferences change, if you don’t want us to send you the information you previously requested, or if you have any queries about how we use your personal data.
Without limiting any other rights you may have, you also have the right to lodge a complaint against us with a supervisory authority in the EU Member State where you are based or in which we are based. Click here to find your local supervisory authority.
Information Received from Market Research Companies in the Netherlands
If you have provided consent to market research companies in the Netherlands to disclose your panel data to Xaxis, then, based on the scope of such consent: we may receive User Information and other information, including panel IDs, from such companies; and we may use this information only for purposes of research and analysis, campaign optimization, advertising customization, and reporting on the effectiveness of online advertising campaigns.
Section 1798.83100 of the California Civil Code provides residents of California with additional rights with regard to their personal information. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
|The right to know about the personal information which we collect, use, disclose and/or sell||You have the right to request that we disclose to you the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information.|
|The right to delete personal information which we have collected from you (subject to certain exceptions)||You have the right to request the deletion of personal information that we collect or maintain about you.|
|The right not to receive discriminatory treatment for the exercise of CCPA rights||Xaxis does not discriminate against you if you choose to exercise your CCPA rights.|
How to Exercise Your CCPA Rights
To submit a request to exercise any of these rights, please contact us by email at email@example.com or by mail to Xaxis, 175 Greenwich Street, 3 WTC, 30th Floor, New York, NY 10007, USA, Attn: Privacy/Legal Department. In any request you submit, you should include clear instructions regarding the information and/or actions you are requesting.
In order to process your request, we may need you to provide additional information to allow us to verify your identity or the authority of any third party submitting the request on your behalf. We do this as a security precaution and to ensure that we do not disclose personal data to the wrong person.
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of “personal information” that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of companies, if any, to which Xaxis has provided personal information for its own marketing purposes, please contact us through email at firstname.lastname@example.org or by mail at Xaxis, 175 Greenwich Street, 3 WTC, 30th Floor, New York, NY 10007, USA, Attn: Legal Department. Please allow 30 days for a response.
Do Not Track
California law requires us to disclose how we respond to browser “Do Not Track” signals or other choice mechanisms relating to Interest-Based Advertising. We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
For more information on opting-out of Interest-Based Advertising, please see the “Opt-Out/Right to Withdraw Consent” subsection of Section 1 above.
Changes to this Privacy Notice
Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).
Other than when acting at the direction of a client or other third party, Xaxis is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you interact with our Services.
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LEGAL - Xaxis, 175 Greenwich Street, 3 WTC, 30th Floor, New York, NY 10007, USA