Our commitment to privacy: Eyereturn
Marketing Inc. (“Eyereturn”), understands that
protecting the privacy and confidentiality of your
information is important to you. This Privacy Code
governs the collection, use and disclosure of your
information in any form, whether written or electronic,
by Eyereturn. This Privacy Code explains what
information may be collected from you and how it is
used. It also explains how you can ask questions, make
suggestions, and express concerns about our privacy
practices.
This Privacy Code applies only to
the information collected by Eyereturn. The collection,
use and disclosure of your personal information is
governed by applicable privacy laws, including the
Personal Information Protection and Electronic Documents
Act (the “Act”), and any applicable provincial
legislation. Eyereturn does not collect any personally
identifying information in connection with the delivery
of our services for our clients, including the
presentation of advertisements or customized content,
nor from the websites and apps in which those
advertisements appear.
If you have any
concerns or questions, we encourage you to contact us
and we will address your concerns to the best of our
ability. Please read this Privacy Code carefully, and
check back periodically as we may update it from time to
time.
WHAT INFORMATION DO WE COLLECT,
AND WHY?
Eyereturn serves
advertisements on behalf of hundreds of third party
advertisers across numerous publisher websites and
mobile applications. Eyereturn also assists our clients
who operate websites to present customized content that
is believed to be more relevant to you.
When
you visit a website or mobile application (“app”) where
Eyereturn is delivering ads, or the site or app of a
customer Eyereturn serves ads on behalf of, or a site or
app where Eyereturn is facilitating custom content,
Eyereturn may collect information about your online
activities and approximate location in order to show you
relevant advertising and content. Eyereturn is exposed
to device latitude and longitude data passed to us via
programmatic media buying opportunities, which in some
cases may describe a precise location. Eyereturn may
store this location information however it is rendered
imprecise prior to use for targeted advertising. We may
collect information such as which ads have been shown
you, on which pages, and how you responded to them. We
may collect information about your interactions with
customer sites—for example, by placing tags on an
advertiser’s web site to measure purchase events for
items they had worked with Eyereturn to advertise or
tags on a web publisher’s site to measure your interest
in particular types of content. Due to the underlying
mechanics of the Internet, Eyereturn is exposed to
information about your device, such as IP address,
unique device identifiers, browser type and language
settings, and operating system information.
TECHNOLOGY
UTILIZED
None of the following
technologies are used to identify individual people.
Rather, they are used to uniquely identify a device or a
browser within a certain level of confidence that
enables Eyereturn to serve more relevant ads and / or
custom content.
Site Tags
Site
tags, also commonly known as pixels or beacons, are used
to help web publishers understand how visitors interact
with their websites and their advertising campaigns.
Site tags are transparent, and maybe HTML image tags,
iframe tags, or JavaScript tags that are installed on a
site. The use of these tags allows a website to measure
the actions of the device loading the page that contains
the tag.
Cookies
If you
load a publisher’s website on which Eyereturn is serving
an ad or delivering custom content, we may assign an
HTTP cookie. A cookie is a small file assigned to your
Web browser that can collect and store information. We
use cookies to better understand how you use websites,
to make sure ads are served correctly, and for analytics
and reporting purposes. For example, a cookie may be
utilized to limit exposure to specific ads. The
information stored in Eyereturn cookies is not linked to
any personally identifiable information.
We
set our browser cookies to expire after two years. The
cookie expiration date will be updated each time a
browser requests resources from our server. Device level
segment data inside the cookie may be retained for the
lifetime of the cookie, in the cookie, however data
stored inside the cookie is aged, and often will be
deleted in a period of hours or days. We collect Non-PII
segmentation data (data which cannot reasonably be used
to identify an individual) in server log files. These
logs are processed daily for aggregated ad delivery and
reporting summaries. The data in the log files cannot be
tied to specific browsers. The summarized reports are
kept indefinitely.
If you are concerned about
cookies, it is possible to turn them off in your web
browser preferences. However, please be aware that by
disabling cookies, your web surfing experience will be
degraded.
We may use IP (internet protocol)
addresses to undertake aggregate browser statistics,
determine the approximate location of browsers, diagnose
problems with our servers, and optimize and administer
our services.
We may track and analyze
Non-PII usage and browsing patterns of visitors to
customer’s websites to provide our advertisers with more
targeted advertising opportunities and to help users see
advertising that is most likely to interest them. We may
also use this information to assist our customers in
presenting customized and more relevant content.
Statistical
IDs
Statistical IDs are created via an
algorithm using non-personally identifiable and
pseudonymous information about a computer or device. The
information used may include the operating system,
user-agent string, Web browser, approximate location,
installed fonts, and similar information. This
information makes your computer or device distinct
enough for our systems to determine within a reasonable
probability that they are encountering the same computer
or device. These IDs are not used to target
advertisements, and are only used for campaign analytics
and reporting purposes. It should be noted that browser
controls do not affect statistical IDs. Statistical IDs
rapidly become obsolete, and generally lose their
linkage to a distinct device in less than one month.
Third
Party Data
We may receive information
about consumers from third parties to enable targeted
advertising on the website(s) and application(s) that we
support. The collection and use of that data is governed
by the privacy policy and legal terms of the data
collector and the website using the data; it is not
governed by Eyereturn Marketing.
SENSITIVE
INFORMATION
Eyereturn does not
collect or aggregate information based on sensitive
health conditions to tailor ads on behalf of our
advertiser clients. In order to provide transparency on
which data segments that are collected and used by
Eyereturn, the health related segments we create are
listed here.
WHO
DOES EYERETURN DISCLOSE INFORMATION TO, AND WHY?
Eyereturn
may disclose your information under the following
circumstances:
Your information may be
processed and stored outside of the province in which
you reside and/or outside of Canada by us, an affiliate
or a third party service provider for the purposes set
out in this Privacy Code and, under the laws of these
other jurisdictions, in certain circumstances foreign
courts, law enforcement agencies or regulatory agencies
may be entitled to access your information.
Eyereturn
may disclose your information to third parties if you
have violated our terms of service, or if we need to
comply with applicable laws and lawful governmental
requests, other legal and regulatory authorities and for
other legal reasons.
For those sites where
Eyereturn assists the publishers with customized
content, Eyereturn may communicate with the publisher
regarding inferred preferences so that the publisher can
tailor the content it presents. These inferred
preferences are limited to categories of interest and no
personally identifiable information is communicated.
CONSENT
AND OPT-OUT POLICY
In general,
Eyereturn seeks consent to use your information in
accordance with our opt-out policy. Except as set out in
this section, eyeReturn obtains your express opt-in
consent to use or disclose sensitive information.
If
you do not wish to have Eyereturn use your information
for tailoring advertisements and the presentation of
customized content, you may opt-out at any time by doing
any of the following:
Web browsers
Please
check your opt-out status below. If you have not
opted-out, you will see an “Opt-out” button. Please note
that if you delete or block party cookies, change Web
browsers, or use a different computer, you will need to
undertake the opt-out again.
Please note that
you will still see ads if you opt out. The ads will just
not be as relevant to you. An opt-out will be effective
with respect to tailored advertising and customized
content. You cannot opt out of one and not the other.
Mobile
Device Applications
Most modern mobile
operating systems (iOS 6, Android 2.3, and Windows 10
and above) provide mobile advertising identifiers for
mobile devices. These identifiers have different names
depending on the brand. For example, they are called
Google Advertising ID (GAID) on Android devices and
Identifiers for Advertisers (IDFA) on iOS. These
identifiers are commonly used to help enable digital
advertising across mobile applications. The operating
systems that provide these mobile advertising
identifiers tend to include built-in settings to express
privacy preferences for online advertising across
applications.
For instructions on how to opt
your device out of Cross-App Advertising, follow the
directions posted here: http://www.networkadvertising.org/mobile-choices
You
may opt-out of interest based advertising and online
behavioural advertising where applicable by clicking the
adchoices icon on ads appearing across our network or by
visiting http://youradchoices.ca/choices/
and https://networkadvertising.org/understanding-online-advertising/what-are-my-options.
General
Notes
Eyereturn is a member of and
conforms to the standards of the following
self-regulatory organizations:
The Digital
Advertising Alliance of Canada (DAAC). To learn more or
to opt out of targeted advertising from other DAAC
members, please visit youradchoices.ca/choices.
The
Digital Advertising Alliance (DAA). To learn more or to
opt out of targeted advertising from other DAA members,
please visit www.aboutads.info/choices.
Generally,
when you provide us with your information, we will
assume that you consent to our collection, use and
disclosure of such information for the purposes
identified or described in this Privacy Code, if
applicable, or otherwise at the time of collection. We
reserve the right to use and disclose your information
without your consent where required or permitted by law,
for example, if we have reasonable grounds to believe
the information could be useful when investigating a
contravention of a federal, provincial or foreign law,
in order to protect or defend our legal interests, or to
comply with applicable laws and lawful governmental
requests.
SAFEGUARDS
Eyereturn
has technical, contractual, administrative and physical
security measures to protect your information in a
manner that is reasonable and appropriate to the nature
of the information you provide to Eyereturn.
Other
than as permitted or required by law, if we wish to
collect, use or disclose your information for purposes
that are not contemplated in this Privacy Code, we will
identify those purposes at the time of collection. You
will be given a reasonable opportunity to opt-out of any
such additional purposes.
HOW TO
ADDRESS CONCERNS REGARDING YOUR PRIVACY
Eyereturn
encourages you to contact us with any questions or
concerns you have about your privacy or this Privacy
Code. If you have a question concerning the Eyereturn
Marketing Inc. Privacy Code please contact us at:
[email protected].
If after contacting
Eyereturn your concerns or questions have not been
resolved to your satisfaction, you can contact
Eyereturn’s Chief Privacy Officer in writing as follows:
Chief
Privacy Officer
Eyereturn Marketing Inc.
1
Yonge, 4th Floor
Toronto, Ontario
M5E 1E6
Fax:
1 (416) 929 6046
This Privacy Code was last
updated in March 2020