Effective Date: March 22, 2017
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.
To learn about how we use data and technology as part of our business to provide digital advertising services to our clients, please see Section 1 below. To learn about how we use data and cookies on the Xaxis Web Site, please see Section 2 below.
Section 1: Xaxis Services
We provide a range of services to our clients, including advertisers, agencies, publishers, and service providers. 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 help ensure that online users receive the most useful and relevant ads and to determine and improve the effectiveness of that advertising.
Types of Information We Collect through Our Services
When you view and interact with Sites and with advertisements where our Services are utilized, we may collect through our Services information regarding your browsing, usage and interactions. We may also collect information that identifies 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 address (“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 may also receive information from other companies, including our clients, that is collected outside our Services and is provided to us for use in connection with the Services. We may integrate that information with information collected through our Services.
How We Collect Information through Our Services
We may collect and utilize information about users and activities across different Sites, and associate it across applicable devices and browsers that we have reasonably linked to the same user. We may also utilize information that we receive from other companies, and associate it with information we collect and across applicable devices and browsers that we have reasonably linked to the same user. These practices are intended to help ensure that online users receive the most useful and relevant ads regardless of device or browser.
How We Use Information Collected through Our Services
We use the information collected through our Services to help ensure that you receive the most useful and relevant online advertising 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, demographic information, prior activity, and similar information (“User Information”), 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:
Such User Information may also be used 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 User Information collected outside the Services for use in connection with the Services, also to help ensure that online users receive the most 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
Our affiliate mPlatform operates and maintains a proprietary data management platform that we and other affiliates may utilize in order to provide services. The information we disclose to mPlatform may be used by mPlatform and such other affiliates not only to provide services to us and our clients, but also to provide services to those affiliates and their respective clients.
We may also 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.
You may opt out of Xaxis Interest-Based Advertising through several mechanisms.
You may choose not to receive customized third-party advertisements via Xaxis targeting cookies on the browser you are using by clicking below, in which case your third-party Xaxis targeting cookie will be replaced with an “opt-out” cookie and the Interest-Based Advertising data previously collected or received in association with the replaced third-party Xaxis targeting 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. In addition, if we have actual knowledge that another device or browser is linked to the opted-out browser, that other device or browser will also be opted out from receiving Interest-Based Advertising via Xaxis.
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 process to work, your browser must be set to accept third-party cookies.
In browser environments, you may also 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 Xaxis and from other providers in addition to Xaxis. However, by doing so, you may not be able to use certain features on certain web sites you visit or take full advantage of all web 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 cookie settings at the level of the web 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 web 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:
In mobile app environments, you may opt out of Interest-Based Advertising from just Xaxis or from both Xaxis and other service providers via the following methods:
- You may select “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from Xaxis and from other providers in addition to Xaxis.
- You may opt out of Interest-Based Advertising via the applicable advertising ID from Xaxis and/or other providers via the AppChoices app. Please note that, in order for the AppChoices app to function properly, your “Limit Ad Tracking” device setting must not be selected. Interest-Based Advertising data previously collected or received in association with the replaced advertising ID will not be used via Xaxis for Interest-Based Advertising on any other device or browser that we have reasonably linked to the mobile app environment where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to the opted-out mobile app environment, that other device or browser will also be opted out from receiving Interest-Based Advertising via Xaxis. Additional information regarding the AppChoices app is available at http://youradchoices.com/appchoices.
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’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, 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 such 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 such applicable self-regulatory framework applies.
Xaxis supports deployment of the Advertising Option icons (AdChoices and 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. 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 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. If you believe a child has provided us with personal information and you would like to have the information removed, please contact us at firstname.lastname@example.org.
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 the “contact us” page) that is in our possession or under our control to the acquiring party.
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. 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.
We generally maintain the information we collect through our Services in non-aggregated form for a period of not more than 13 months. This data includes Sites visited, content viewed, ad interactions, IP addresses (please see the “IP Address” subsection below for additional information), browser type and language settings.
We may maintain information we collect through our Services in an aggregated form for a period longer than 13 months.
Please note that in some countries an IP address is considered personal data by applicable law. If we collect information from any such country and we know that you are located in that country, we will treat your IP address as personal data.
For those 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 addresses for those countries do not touch Xaxis’s systems and are not processed by Xaxis in connection with the provision of Services.
Section 2: Xaxis Web Site
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 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 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
For more information about the specific cookies Xaxis uses on the Xaxis Web Site, please click here.
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.
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.
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 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. For more information on opting-out of Interest-Based Advertising, please see the “User Choice” subsection of Section 1 above.
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 and to have any inaccuracies in your personal information corrected. For these purposes, please contact us at email@example.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 firstname.lastname@example.org.