Effective Date: January 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.
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.
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.
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
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.
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 turn off our cookies, as well as the cookies of other service providers, via 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 ‘turn off’ all third-party Interest-Based Advertisements from us and other participating EDAA member companies via cookies, please click here.
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 firstname.lastname@example.org.
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.
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.
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.
Europe and Safe Harbor Principles
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.
We comply 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.
We have certified that we adhere 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 our certification, please visit http://www.export.gov/safeharbor/.
Xaxis has committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles, to the extent in effect, to an independent dispute resolution mechanism, the BBB EU Safe Harbor Dispute Resolution Program, 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 Dispute Resolution Program Site at www.bbb.org/us/safe-harbor-complaints, to the extent in effect, for more information or to file a complaint.
How Information is Used and Shared on 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.
We comply 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. To learn more about the Safe Harbor programs, and to view the company’s certification, please visit http://www.export.gov/safeharbor.
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.
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.
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.
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 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.