• Privacy Policy

    Xaxis Privacy Policy

    Effective Date: July 29, 2016

    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.

    The purpose of this Privacy Policy is to provide clear notice about the information we may collect in connection with our Services (as defined in Section 1 below), including activities we undertake across web sites, applications and other digital properties (collectively, “Sites”), and on our corporate web site, www.xaxis.com (“Xaxis Web Site”), which is operated by Xaxis, Inc.  

    For information on how we use data and cookies as part of our business to deliver digital advertising services for our clients, please see Section 1 below.  For information on how we use data and cookies on the Xaxis Web Site, please see Section 2 below.

    Except as expressly stated otherwise, the use of information by our non-Xaxis affiliates, our clients and our service providers is not covered by this Privacy Policy.  

    Please note that because of the changing nature of privacy laws and regulations, user needs, and our business, we may modify this Privacy Policy from time to time.  Accordingly, since we want to help you clearly understand our privacy practices, we encourage you to review this Privacy Policy periodically to become aware of any changes that may have occurred.  You can determine when this Privacy Policy was last revised by referring to the “Effective Date” above.

    If you have questions or concerns regarding this Privacy Policy, please contact us through email or by mail.  You can address your general questions and comments by e-mail to privacy@xaxis.com or by mail to us at c/o Xaxis, Inc., 132 West 31 Street, 9th Floor, New York, NY 10001, Attn: Legal Department.

     

    Section 1: Xaxis Services Privacy Policy and Cookies

    Xaxis’s Services

    We provide a range of services to our clients, including advertisers and publishers.  Xaxis’s services (“Services”) include: media planning, buying and selling; marketing communications planning; campaign analytics and research; paid search placement; search engine optimization; and audience segmentation and data management.  Our clients use our Services in order to show online users the most useful and relevant ads.  For purposes of this Privacy Policy, Xaxis’s Services do not include the services of Xaxis’s Light Reaction performance marketing division.  For information on how Light Reaction collects and uses information through its services (as opposed to the collection and use of information through the Services or on the Xaxis Web Site), please click here. 

    Types of Information We Collect through Our Services

    When you view and interact with Sites and with advertisements operated by our clients (and, in some cases, by our clients’ clients), we may collect through our Services information regarding your browsing, usage and interactions.  We may also collect information that allows us to identify browsers and devices we have interacted with previously.  Such information collected through our Services may include the type of Internet browser, browser language, and operating system you use, your device’s Internet protocol (“IP”) address, unique identifiers available at or pertaining to your device, connection type (wired or Wi-Fi), region where your device is located, network to which your device is connected, longitude/latitude of a (mobile) device, mobile carrier (if available), the Site and page you came from before, and visited after, viewing an advertisement, and information related to the Site and page you are viewing (i.e., in order to ascertain your interests).  Devices include computers, mobile phones, tablets, e-readers, or other digital devices capable of maintaining an Internet connection.   

    We do not collect users’ names, mailing addresses, phone numbers, email addresses or similar personally identifiable information through our Services.  

    We collect information through the use of cookies, pixels and other technologies.  A cookie is a small text file that is stored in a browser by a Site or ad server which allows that Site or ad server to recognize that browser and remember user preferences and other information.  A pixel is a line of code that is used by a Site or third party to assign online activities to a device or browser.  The use of a pixel allows Sites and us to record, for example, that a user has visited a particular Site or page.  Additional information from an earlier period or interaction, which may include interest, demographic or other information intended to provide users with more useful and relevant online advertising, may be included in the pixel.

    How We Use Information Collected through Our Services

    We use the information collected through our Services to provide you with the most useful and relevant online advertising and to better customize the sort of advertisements you see on Sites (including on web sites in a browser environment and/or in applications, and on other devices and browsers that we have reasonably linked to the device and/or browser where the information was collected) (we refer to customized advertising based on users’ interests as “Interest-Based Advertising”).  For example, if we think that a user is interested in apparel options, then our Services may help our clients deliver Interest-Based Advertisements to that user about a particular type of apparel, as follows: 

      

    We also may use such information to limit the number of times you see a particular ad, and for other purposes such as research, reporting and analysis in order to deliver the most useful and relevant advertising and to determine and improve the effectiveness of that advertising. 

    We may also receive from other companies information collected outside the Services for use in connection with the Services on behalf of our clients, also to enable us to deliver useful and relevant advertising and to determine and improve the effectiveness of that advertising.  We do not associate such information with your name, mailing address, email address or similar personally identifiable information. 

    We require our clients to comply with applicable laws governing online privacy.  We encourage you to read the privacy policies of the Sites you visit to better understand issues relating to your online privacy.

    Disclosure of Information to Third Parties

    We may disclose the information we collect about you (see “Types of Information We Collect through Our Services” above), and information derived from it, to our clients and service providers.  As we do not collect users’ names, mailing addresses, phone numbers, email addresses or similar personally identifiable information through our Services, we do not disclose any such information to third parties.  However, if you decide to provide personally identifiable information via one of our clients’ advertisements or Sites, then that information will be received by that client and will be subject to that client’s privacy policy.  Our service providers are not permitted to use non-aggregated information we disclose to them for any purpose other than providing services to us or our clients.

    Xaxis, Inc. operates and maintains a proprietary data management platform that affiliates controlled by Xaxis, Inc., including Light Reaction, utilize in order to provide services.

    We also may disclose the information we collect to third parties, including law enforcement, 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.

    Disclosure of Information to Market Research Companies

    We may disclose the information we collect about you to market research companies, which companies can add demographic, interest, and similar information to the information collected by us. We may aggregate this information together with the information we collect about you, for purposes of research, reporting, analysis and optimization of online advertising campaigns.

    User Choice

    We collect information through our Services via the use of cookies, pixels and other technologies.  We believe that the use of these technologies enables us and our clients to provide users with a more useful digital experience.

    You may simply choose not to receive customized third-party advertisements via Xaxis cookies on the browser you are using by clicking below, in which case your unique third-party Xaxis cookie will be replaced with a non-unique “opt-out” cookie and the Interest-Based Advertising data previously collected or received in association with the replaced unique third-party Xaxis cookie will not be used for Interest-Based Advertising on any other device or browser that we have reasonably linked to the browser where the information was collected:

    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 delete this opt-out cookie, you will need to perform the opt-out process again.  In order for the opt-out to work, your browser must be set to accept third-party cookies.   

    You may also opt out from Xaxis cookies, and in some cases refuse or remove cookies from both Xaxis and other service providers, via the following methods:

    • You may adjust your browser settings to refuse or remove cookies, which would result in the elimination of Interest-Based Advertising via cookies from other providers in addition to Xaxis.  However, by doing so, you may not be able to use certain features on the Sites you visit or take full advantage of all Site offerings and Interest-Based Advertising.  You may refuse or remove cookies by following the directions provided in your browser settings.  Further information about cookies is available at www.aboutcookies.org, www.youronlinechoices.com and http://www.aboutads.info/consumers#cookies. 
    • You may adjust the initial cookie settings at the level of the Site owner where you granted us your consent to our cookie usage, to the extent made available by the cookie settings deployed by the applicable Site owner.
    • You may simply opt out of Interest-Based Advertising via our cookies, as well as the cookies of other service providers, at the following Sites:

    You may also choose not to receive customized third-party advertisements from Xaxis and other service providers in a mobile app environment (instead of via cookies in a browser environment) by selecting “Limit Ad Tracking” via your mobile device settings.

    Network Advertising Initiative 

    We are a member of the Network Advertising Initiative (NAI) and adhere to the NAI’s Codes of Conduct in those markets where these self-regulatory frameworks apply and are in effect.  In accordance with the Codes 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 NAI member companies.

    Digital Advertising Alliance, IAB Europe, and Ad Choices

    Xaxis supports deployment of the Advertising Option icons (AdChoices and AppChoices) as part of its participation in the Digital Advertising Alliance’s self-regulatory framework (in North America) and the IAB Europe OBA Framework (in Europe).  Advertisements that are provided by organizations that participate in these frameworks will display the icon displayed below when technologically feasible.  If you click on the icon displayed on an ad, you will receive information about Interest-Based Advertising.

      

    You can click here to reach the Digital Advertising Alliance site, which has additional information about Interest-Based Advertising and the Digital Advertising Alliance’s self-regulatory framework, as well as a mechanism to opt out of receiving third-party Interest-Based Advertising via cookies from us and DAA member companies.

    European Interactive Digital Advertising Alliance

    We are a member of the European Interactive Digital Advertising Alliance (EDAA) and, in connection with our membership, adhere to the IAB Europe EU Framework for Online Behavioral Advertising in those markets where that self-regulatory framework applies.  For information about Interest-Based Advertising and the choices available to you, and to opt out of third-party Interest-Based Advertisements from us and other participating EDAA member companies via cookies, please click here.  

    Children’s Privacy

    We are sensitive to the issue of children’s privacy.  Therefore, neither the Services nor the Xaxis Web Site is developed for, or directed at, children or at Sites primarily directed to children.  If you believe a child has provided us with personal information and you would like to have the information removed, please contact us at privacy@xaxis.com.

    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 information a user may have provided through the “contact us” page) that is in our possession or under our control to the acquiring party.

    Information Security

    We follow generally accepted 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.  Any data that is stored on our servers is treated as confidential information.  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.  Therefore, while we strive to protect such data at all times, we cannot guarantee its absolute security and shall not be liable for any breach of security in relation to any such data.

    We are a global company and therefore we may transfer data to countries around the world, including countries outside your country or your continent.  We will, where necessary, put in place appropriate safeguards to ensure such data is protected.

    Data Retention

    We generally maintain the information we collect through our Services in non-aggregated form for a period of not more than thirteen months.  This data includes Sites visited, content viewed, ad interactions, IP addresses (please see the “Europe” subsection below for additional information about IP addresses), browser type and language settings.

    We may maintain information we collect through our Services in an aggregated form for a period longer than thirteen months.

    IP Address

    Please note that in some countries an IP address is considered personal data by applicable law.  If we conduct business in any such country and we know that you are located in that country, we will treat your IP address as personal data.

    In these countries we interpose a “black box” that is operated by an independent third party and that separates the user’s IP address from other data we collect.  As a result of this black box, IP address in those countries does not touch Xaxis’s systems and is not processed by Xaxis in connection with the provision of Services.

     

    Section 2: Xaxis Web Site Privacy Policy

    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 Privacy Policy contains important information about how we use your personal information collected via the Xaxis Web Site.  

    What Information Do We Collect? 

    When you use the Xaxis Web Site, we may gather the following information:

    - Information (which may include personal information such as name, address, email address, and telephone number) provided by you when you submit your CV or a job application to us or request information from us

    - IP address and/or cookie ID

    If you provide us information through our “Contact/Contact Us” link 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 such 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?

    We will use this information in the following ways:

    - To provide you with information that you have requested;

    - To respond to specific queries you may raise regarding Xaxis, its business, the services it provides to clients and any of its group companies; 

    - To improve the content, speed, and security of the Xaxis Web Site; and/or

    - To process and consider your CV and/or job application.

    Do We Pass Your Information to Third Parties?

    We may send your information (including your personal information) to our affiliate GroupM, service providers and other third parties to help us process that information for the purposes set out in this Section 2 of this Privacy Policy.  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 information) to the acquiring party.

    We also may disclose your information (including your personal information) 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 to countries around the world, including countries outside your country or your continent.  We will, where necessary, put in place appropriate safeguards to ensure your information is protected.

    How Long Do We Keep Your Information?

    We will keep your information for a reasonable period for the purposes set out above, usually for between 12 to 18 months from the date of receipt.

    Linking to Other Sites

    A link from our own Site to another Site does not imply our endorsement of that Site.  We do not control the Sites 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 Sites you access from our Site.

    Use of Cookies on the Xaxis Web Site

    A cookie is a small text file that is stored in a browser by a website or ad server which allows that website or ad server to recognize that browser and remember user preferences and other information.  (For more information on cookies, please see Section 1 above.)  We use cookies on the Xaxis Web Site to improve the content, speed, and security of the Xaxis Web Site, and to allow you to share pages with social networks.

    For more information about the specific cookies Xaxis uses on the Xaxis Web Site, please click here.

    Managing Cookies

    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 “User Choice” subsection in Section 1 above.

    Third-Party Sites

    Our website links to third-party Sites.  These Sites may use cookies and collect your personal information in accordance with their own privacy policies.  This Privacy Policy does not apply to third-party Sites, and we are not responsible for third-party Sites or their policies or practices.

    How Do We Protect Your Information?

    We take appropriate measures to ensure that your personal information 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.

    Children 

    The Xaxis Web Site is not intended or designed to attract children. We do not knowingly collect personal information from children.  If you are a child and wish to ask a question or use this site in any way which requires you to submit your personal information, please get your parent or guardian to do so on your behalf.

     

    Section 3: State and Country-Specific Information; Contacting Us

    California

    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 via the email alias or address stated in “Questions or Comments about this Privacy Policy” below.  Please allow 30 days for a response.

    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. 

    We are committed to honoring your privacy choices, and, as noted in the “User Choice” subsection of Section 1 above, we provide a mechanism that allows you to opt out of Interest-Based Advertising via Xaxis cookies.

    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 demographic (such as age, gender, education, income, and household status (e.g., number of children)), interest, and similar information, and 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. 

    How to Obtain a Copy of Your Information

    You are entitled to know what personal information we hold about you (for which we may charge a small fee) and to have any inaccuracies in your personal information corrected.  For these purposes, please contact us at privacy@xaxis.com.

    How to Contact Us if Your Information or Preferences Change

    If your personal information or your preferences change, if you don’t want us to send you the information you have requested or if you have any queries about how we use your personal information, please let us know by contacting us at privacy@xaxis.com.