Feathr runs a marketing platform. The Feathr Technology allows our Customers to buy ad space on websites for online advertising and allows for the use of proprietary and third party data in the purchase of that media. When ad space on or within a website or mobile application is bought or sold (usually to an advertiser or ad agency by a web publisher) the Technology, fulfills the transaction by delivering the ad to Internet and mobile users who visit that site or use that application. Generally, an Internet user’s computer comes into contact with Feathr when a user views an ad, opens an email, or visits a website, delivered or serviced by or with our Technology. Serving users relevant advertising is sometimes referred to as interest based advertising or online behavioral advertising, also known as “IBA” or “OBA”
Last Edited on 2018-06-19
Our fundamental principal is that when advertising is tailored to a user based on their interests and behavior, it is mutually beneficial to the user and the business wishing to engage with them. To do this, we collect a variety of data from Customers and across platforms, including from other third party platforms and providers, to help optimize ads and increase the likelihood that a particular unique, but anonymous users will be interested in an ad they see.
- Our Technology collects Non-Personally Identifiable Information (“Non-PII”) that may include, but is not limited to, your IP host address, the date and time of the ad request, pages viewed, browser type, the referring URL, Internet Service Provider, and your computer’s operating system, as well as how you interact with a web page or ad. We may also receive Non-PII such as age, gender, income, education, interests, and usage activity from Customers or other third parties, such as other data and advertising platforms we work with. We may assign a unique, non-PII identifier to your browser or device, such as an identifier associated with a “cookie” on your browser, and this identifier may likewise be associated with any other (anonymous or de-identified) information we have collected about, or otherwise learned or inferred about you.
- We also may collect or receive analogous Non-PII from mobile platforms or applications, which may include information about your interactions with those platforms or applications (including your IP address and time-stamp information), your precise geolocation information (such as latitudinal and longitudinal coordinates), and information about your mobile device (including device type, handset name, operating system information, mobile identifiers such as Apple IDFA and Android Advertising ID, app-specific identifiers, and a list of the applications your device interacts with).
- Sometimes, we obtain the above information from other ad platforms, application platforms or providers, customers or websites and services (including our Customers).
- Customers may also choose to provide us with personally identifiable information such as an email address, name, username or other identifier or any other PII.
How We Use Information Collected
Feathr uses Non-PII and, if it is provided to us by a Customer, to target and serve relevant advertising to users and to perform attribution analysis or other analytics regarding advertising audiences, as well as to compile, match and link audiences on behalf of Customers. For instance, we may use information, generally on behalf of Customer, to:
- Determine what ad to show a user, and customize ads to particular types of audiences;
- Customize ads to the type of web page users are viewing;
- Limit the number of times a user sees an ad or a type of ad;
- Perform analysis of how effective ads are;
- Help advertisers learn more about their own users.
Sometimes we may use or make available to Customers the Non-PII we collect or receive (such as IP Address) to recognize users or try to resolve a commonality of users (or households) across platforms or across devices, such as smartphones, computers, tablets or related browsers. For instance, we might infer that a common IP address seen across different devices represents a common user (or a related or similar user), and use that inference in tailoring ads. If a Customer provides us with PII, we may also use PII, or a combination of PII and Non-PII for this purpose. Occasionally, we use or create anonymized data sets (which may constitute hashed or obfuscated personally identifiable information), in order to promote, test or validate the accuracy of such inferences.
Cookies and Web Beacons
Cookies are small text files that web servers typically send to users’ computer when they visit a website. Cookies are stored as text files on users’ hard drive, and can be accessed by web servers when the user visits a website or views an advertisement. Cookies are used by companies to collect and send information about a user’s website visits – for example, number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. This information helps companies improve a user’s online experience in many ways: for example, by allowing companies to monitor website performance, making the website easier to use, measuring the effectiveness of their promotional placements, and tailoring their website (including the ads and offers they receive) to better match a user’s interests and preferences. Users who prefer not to accept cookies can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive.
Feathr also uses web beacons (also known as 1×1 gifs), along with cookies, to determine if a user has visited a particular website. These beacons aid in providing more relevant advertising to the user, as well measuring the success of an advertising campaign, but provide no personally identifiable information.
Feathr may share the non-PII that we collect and receive in various ways.
- Primarily, we may work with Customers and other third parties to help optimize ads and make them more likely to be relevant to users, by comparing, syncing and sharing the non-PII described above. For instance, we may disclose to other ad platforms, customers or websites and services (including our Customers), non-PII we have collected (generally, unique, anonymous identifiers representing users’ browsers), to match their unique identifiers to our own, so that we can “sync” identifiers in order to help them show more relevant ads, match users to their likely interests, or better synchronize, cap, or otherwise optimize advertising.
- Finally, we may share aggregated, non-personal information with Customers in connection with reporting and accounting needs as well as with other unaffiliated third parties for various purposes such as statistical or educational analysis (such as the creation of predictive models).
Feathr may share the PII provided to us by a Customer with that Customer for the provision of services to that Customer and as set forth in this policy, including in order to assist Customers with targeted advertising. We may sync or combine Non-PII that has been shared with third parties (as set forth above) with PII, and we may share the combined data with the Customer who provided us with the PII.
We may also share PII, Non-PII or any combination thereof:
- to be processed on our behalf by third-party service providers that assist us in running our business, including providers of data storage and processing facilities.
- we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual activities that may harm any person, our company, the Technology, or otherwise violate any law.
- Also, in the event Feathr is merged into another company, or another company acquires all or substantially all of Feathr’s assets, including, without limitation, in the event of bankruptcy, all data compiled or owned by Feathr may be among the items transferred in that transaction.
Your Opt-Out Choices
You can opt out of receiving personalized ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by visiting our Privacy Platform. Please note that this “opt out” function is browser-specific and relies on an “opt out cookie”: thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again or make sure to opt out from the device you intend to remove from targeting and personalization.
The online advertising industry provides websites from which you may opt-out of receiving targeted ads from our data and advertising partners. You can access these, and also learn more about targeted advertising and user choice and privacy, at http://www.aboutads.info and at http://www.networkadvertising.org/choices/. If you are located in the EU you can access this information at http://www.youronlinechoices.eu.
If you are an EU citizen you have additional rights afforded to you under the General Data Protection Regulation (GDPR) described below.
GDPR Data Protection Rights
If you are a resident of a European Territory, you have the following enhanced rights and modes of executing them through Feathr:
- If you wish to access, correct, update or request deletion of your personal information, you can contact us using the contact details provided under the “Contact us about questions or concerns” heading below. You can further object to processing of your personal information, ask us to restrict processing of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting Us" heading below.
- If we have already collected and processed your personal information with your consent, then you can withdraw or modify your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can withdraw consent for us or our partners to drop our tracking cookies and our partners’ cookies by visiting our Privacy Platform or by withdrawing consent for Feathr when you see an IAB compliant “consent management platform” on a publisher or advertiser site which lists Feathr as a participating vendor.
Please note that we have no direct relationship with the individuals whose personal data we process on behalf of our clients and partners. Where we act as a processor for our clients and partners (for example, with respect to our email products), you should direct any requests to access, correct, update, or delete your personal data to the respective client or partner. We will respond to any requests by a client or partner to provide assistance with such requests within 30 days.
Data Storage and Security
We retain the both PII and Non-PII collected via our Technology for up to 24 months. After 24 months (or sooner) Non-PII data is stored in aggregate for up to three years and PII is destroyed.
The security of your information is important to us. Feathr has implemented security measures to prevent the loss, misuse, and alteration of the information that our Technology collects, but we make no assurances about our ability to prevent such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.
Changes To Our Policy
Feathr operates the Technology from servers located in the United States of America and the information it collects through Customers is processed in the United States of America. Laws governing the collection and use of data in the United States may not be equivalent to those in the country where you reside, but Feathr will at all times protect your data in accordance with this Policy.
Should you have any questions in regards to this policy or Feathr’s privacy practices, please contact our representatives at the following email and they will be more than happy to clarify and assist you in any way possible: email@example.com, or by mail at:
What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.
When do we collect information?
We collect information from you when you subscribe to a newsletter, fill out a form or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To administer a contest, promotion, survey or other site feature.
- To send periodic emails regarding your order or other products and services.
How do we protect visitor information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
All credit card transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use ‘cookies’?
- Understand and save user’s preferences for future visits.
- Keep track of advertisements.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If users disable cookies, some features will be disabled. It will turn off some of the features that make your site experience more efficient and some of our services will not function properly.
Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Fair Information Practices
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
- We will notify the users via email within 7 business days
- We will notify the users via in site notification within 7 business days
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.