Publication date: May 25, 2018.
Archived versions may be accessed here.
For information on interest-based advertising, including to understand what opting-out means and your opt-out choices, please see the section headed “Opt-Out and Your Choices” below. To actually review your choices and set your control and opt-out options for your devices, including computer browsers and mobile browsers and devices, you must visit our Opt-Out Options and Additional Information section here.
Privacy Practices for Our Sizmek Websites (www.sizmek.com)
Privacy Practices for Advertising and Content Served by Sizmek
We respect your right to privacy throughout all of the services we provide. In particular, as a member of the Network Advertising Initiative (NAI), Sizmek adheres to the NAI Codes of Conduct as well as the principles of the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance’s (EDAA) regarding our use of data for interest-based advertising purposes. We also comply with the policies of the IAB Europe Transparency and Consent Framework, as a registered vendor on the Global Vendor List. For more information about these organizations, their policies and interest-based advertising, please visit their websites by clicking on the following links: NAI (here), DAA (here), EDAA (here), or the IAB Europe Transparency and Consent Framework (here).
Data Collection through Sizmek Services
What do Sizmek’s Services do?
Through our services, our customers – advertisers, advertising agencies, publishers, and other users of Sizmek services – may collect and use information about your device to provide you with a more tailored online advertising experience. Our customers use Sizmek’s tools and services to create and deliver advertisements, to monitor the success of and manage advertising campaigns, to detect and minimize advertising fraud and, ultimately, to present you with advertisements that are more likely to be interesting and relevant to you. Delivering relevant ads that are tailored to users’ interests is known as “interest based advertising” (sometimes also referred to as “behavioral advertising” or “targeted advertising”).
How does interest based advertising work?
To perform interest based advertising, Sizmek’s cookies and similar technologies (described below) are deployed on your devices, and through the third-party websites and mobile applications you use, to collect information about your interests and behavior on the internet. The information we collect is associated with your cookie identifiers and/or mobile advertising identifiers (if you are using a mobile device), as well as your IP address. We never collect information about your actual identity.
We use the information we collect for online ad tailoring purposes or to deliver an advertisement to you from a company whose website or mobile application you have visited or whose advertisement you have viewed in the past. As explained above, our technology employs cookies, device identifiers and similar technologies (like pixels and statistical device identifiers) to collect information about your browser or device, the sites it has visited and the apps it has used, the advertisements served to it, interactions with those advertisements, and, where available, the approximate geographic location of the device (“behavioral information”). This behavioral information is collected in the course of providing our customers with ad-serving and campaign management services and used for the purpose of helping our customers determine which advertisement is suitable to be delivered to you.
This behavioral information, which does not enable Sizmek to determine your actual identity, may be shared with our customers and Sizmek’s and our customers’ partners for their lawful advertising purposes. In some areas of the world, certain behavioral information, such as IP addresses, cookie identifiers and device identifiers, may be considered to be personal information (sometimes referred to as personal data) that is protected under applicable laws. Where this is the case, we comply with applicable laws regarding our use and processing of personal information.
Cross-device interest based advertising
We use the term “devices” to refer collectively to computers and mobile devices, as well as the internet browsers and other applications on your devices that interact with the internet. Sizmek engages in cross device data collection which refers to the process of collecting data from separate devices that have been determined through statistical analysis to be linked or related. Sizmek, or partners that we employ to provide this service, use cross device data to provide interest based advertising services to our customers and to deliver tailored ads to users across multiple devices.
Information Collected by Customers and their Partners
Please note that Sizmek customers sometimes include their own (or their partners’) ad-tags, pixels or similar technologies within advertisements that Sizmek serves to websites, in order to set and read their own cookies which Sizmek does not control.
Sizmek is not responsible for and cannot control the data collection and use practices of its customers or their partners. You should read the privacy notices of the websites you visit and the online services and interactive ads that you use to understand what information companies collect and how they use that information.
Sharing of Behavioral Information with Customers
We share the behavioral information collected from our advertising technologies with our customers and partners for their lawful advertising purposes. We may also share behavioral information with our customers’ service providers to enable them to provide services on our customers’ behalf or to partner with us in selecting and serving ads for our customers. We use reasonable efforts to require our customers and partners to treat the behavioral information we share with them in accordance with applicable laws, the terms of the contracts we may have with them, and their own privacy policies, but cannot control their use of this information.
Information Sizmek Collects on Behalf of Third Parties
Links to Other Sites
Sizmek, our customers, and our respective partners collect behavioral information to create interest segments. An interest segment is a set of profiles of users or their devices that are grouped according to user characteristics or interests, such as “Autos,” “Travel” or “Cooking.” Each profile is an anonymous or pseudonymous identifier that is tied to users’ devices. As a user’s device interacts with ads, websites and mobile applications, the characteristics and interests of the users of such devices can be collected and inferred. These characteristics and interests are represented by the identifier associated with your device, and then grouped with other, similar identifiers to create an interest segment. Sizmek, our customers and our respective partners use interest segments to deliver ads to your devices that are related to your interests. We require our partners to treat the information used to create these segments in accordance with applicable laws, the terms of our contracts with them, and their privacy policies. You can opt-out of interest based advertising based on interest segments at any time, as described under the heading “Opt-Out and Your Choices” below.
We also receive interest segments and other pseudonymous information from third parties, when they choose to provide it to us and are lawfully permitted to do so. This information may include identifiers (like mobile advertising IDs) and interest-based advertising data tied to those identifiers, including segments provided by third-party data providers for our clients to use in delivering tailored ads through Sizmek’s services. Sizmek does not use this data to determine your actual identity.
Sizmek does not knowingly create or use interest segments based on sensitive categories such as race, religion, sexual orientation or health; however, Sizmek, our customers and our respective partners may use interest segments related to health (which are not comprised of sensitive health data) to provide tailored ads that may be of interest to you.
Data Security and Retention
We have appropriate technical and organizational security measures in place to help protect the personal information that is submitted to us voluntarily through our web site or collected through interactions with our services. However, no system can be completely secure, and we make no guarantees as to the safety or security of any information transmitted to or from this site or through our services. Sizmek retains information we receive from your device in log files that is stored for up to 13 months from the time it is stored, after which time the log files are deleted.
This section provides additional information about the various technologies that Sizmek uses to deliver ads to you and services to our customers, including services that collect behavioral information when you interact with our customers’ ads or the sites and applications where their ads are provided. To learn how to control or opt-out of our use of these technologies, including to understand what opting-out means and your opt-out choices, please read the section, “Opt-Out & Your Choices” below. If you wish to exercise your control or opt-out options, visit our Opt-Out Options and Additional Information section here.
To learn more about the cookies we serve when you visit the Sizmek website (including how to opt-out of them), please visit our Cookie Consent link in the lower, left corner of our website.
Mobile Advertising Identifiers
Like most websites and advertising services providers, we gather certain information about your use of the Sizmek website and services automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not allow us to determine your actual identity, to analyze trends, to administer the site and services, to track users’ movements around the Sizmek website and the devices to which we provide advertisements, and to gather demographic information about our users who interact with our services as a whole. We obfuscate IP addresses in any reporting information that is shared with or made available to our clients.
Pixels (also known as Clear Gifs)
We or third-party advertising services providers selected by our customers may employ advertising pixels (a.k.a. clear gifs) on websites and advertisements that interact with some of our services. Pixels help us and our customers better manage content and advertising on websites by informing us what content is effective. Pixels are graphics embedded invisibly in web and advertising content and are about the size of the period at the end of this sentence. Pixels work with cookies to record the interactions of users with websites and advertisements.
Statistical Identifiers and Cross-Device
We may employ a technique known as statistical identifiers (a.k.a. device recognition). Like pixels, they help us and our customers to better manage content and advertising on devices by informing us (without using cookies) of the content with which users interact. Statistical identifiers collect various information about your device, such as your screen resolution, browser type, operating system and so on. Many devices have unique, or near unique, device profiles and so collecting this information enables us to determine to a reasonable level of statistical accuracy the level of users’ engagement with our or our customers’ advertisements and websites and to recognize the devices of users who interact with our or our customers’ content. We do not tie the information gathered through the use of statistical identifiers to any information that enables us to determine an individual’s actual identity. Sizmek’s cross device solutions attempt to use statistical identifiers to tailor your advertising experience across all of your devices, such as your computer, mobile phone and tablet. For example, using Sizmek’s cross device solutions, advertisers can limit the number of times you see the same ad on multiple devices, or serve you a follow-up ad on your computer after you have seen a related ad on your mobile device.
Precise Location Data
Precise location data refers to the precise location of your device at a specific time. It is derived through technologies that are capable of determining with reasonable specificity the actual physical location of an individual or device, such as GPS-level latitude-longitude coordinates or location-based Wi-Fi triangulation. Sizmek uses precise location data to provide ads and other services to you in real time, if you consent to such use. If we obtain such data from our partners, we require them to obtain your consent before providing it to us.
Opt-Out & Your Choices
To review your choices and set your opt-out options for your devices, including computer browsers and mobile browsers and devices, you must visit our Opt-Out Options and Additional Information section here.
Sizmek allows consumers to opt-out of Sizmek using our ad-serving cookie, mobile advertising identifiers, statistical identifiers and precise location data to serve online ads tailored to the consumer’s interests. Refusing cookies or use of mobile advertising or statistical identifiers or location data does not stop advertisements from being served to your computer or mobile device; rather, it means that Sizmek will not collect and use data related to cookies, mobile advertising identifiers or statistical identifiers, or precise location data to serve targeted advertisements to you. Please note that if you choose to opt out, we will be unable to serve you ads tailored to your interests, and you may receive the same ad multiple times. The Opt-Out Options and Additional Information section provides additional information to help you understand digital advertising and your choices for receiving interest-based ads.
Your Advertising Choices and Third Party Services
Through our services and platform, our customers have access to services provided by third party companies with which Sizmek or our customers have partnered to assist our customers in delivering more relevant ads to you. If you would like to learn more about the practices of some of these companies and to make choices about their use of your information, please visit the sites of the NAI, DAA and EDAA for more information. Links to these sites, including services that permit you to opt-out of interest-based advertising by some of Sizmek’s partners, are provided in the section, Advertising Industry Sites for Control of Interest-Based Advertising on our Opt-Out Options and Additional Information section here. Some of our partners may not be covered by the NAI, DAA or EDAA programs, and you should consult the privacy policies on their websites for more information and to make choices about their services.
Do Not Track Disclosure
Do Not Track (“DNT”) is a privacy preference that users may set in certain web browsers. DNT is intended to allow users another method of informing websites and services that they do not want certain information about their website visits collected over time and across websites.
At present, we respect DNT signals that we believe are the result of an active choice made by the user; however, we do not recognize or respond to DNT signals from browsers or devices that turn these on by default. Please note that the online service and advertising industries currently are still working toward defining what “DNT” means, and devising a common approach to responding to DNT, and we may therefore change our treatment of DNT signals once a common approach is agreed.
Social Media Features
Information Relating to Children
Our products and services are not designed or intended for children (as defined in applicable data protection laws). We do not knowingly collect personal information from children on the websites we operate or through our services. Please advise us if you are aware of our having received personal information from a child, in which case we will take appropriate steps to delete it. For these purposes, “children” and “child” refer to ages defined by applicable law in the countries where we provide our services.
International Data Transfers and Our Privacy Shield Compliance
The personal information Sizmek processes may be transferred to, and processed in, any country in which we, our group companies, or our service providers or partners operate, and this may include countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Sizmek US has further committed to refer unresolved privacy complaints from EEA or Swiss citizens or residents regarding transfers of their personal data under the Privacy Shield Principles to a non-profit alternative dispute resolution provider, the BBB EU PRIVACY SHIELD, located in the United States and 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, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel for EU or Swiss individuals.
When Sizmek US transfers personal information about EU or Swiss individuals to other third parties, it will do so in accordance with the Onward Transfer principle of the EU-US and Swiss-US Privacy Shield Principles. In these cases, Sizmek US is potentially liable if such third parties do not provide the same level of protection as the Privacy Shield Principles.
IAB Europe Transparency and Consent Framework
Where publishers have chosen to integrate an advertising consent interface on their sites or apps that conforms to the requirements of the IAB Europe’s Transparency and Consent Framework, we will respect and comply with the signals that are passed to us in accordance with the Framework.
Legal Basis and Purposes For Processing
If you are a user from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally process personal information from you only where we have your consent to do so (including as a processor for a third party data controller that has obtained your consent), where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to process your request to exercise your rights regarding your personal data or that of another person who shares your device).
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “If You Have Questions About This Policy” heading below.
Your Data Protection Rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “If You Have Questions About This Policy” heading below or via this web service.
- In addition, if you are a resident of the European Economic Area, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “If You Have Questions About This Policy” heading below or via this web service.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “If You Have Questions About This Policy” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw 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 have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)
- We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Other Third Party Disclosures
We may disclose your personal information to the following categories of recipients:
- To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
To any other person with your consent to the disclosure
Changes to this Document
If we make material changes to this policy we will notify you by means of a prominent notice on the Sizmek website, or directly where we have the means to do so, prior to the change becoming effective. We will obtain your consent to any material changes where we are required to do so by applicable data protection laws. We encourage you to review this page periodically for the latest information on our privacy practices.
If You Have Questions About This Policy
If you are a visitor from the European Economic Area, the controller of any personal information processed about you by Sizmek is Sizmek, Inc., who can be contacted using the details provided above. Sizmek’s representative in the European Economic Area may be contacted as firstname.lastname@example.org.