Who we are
Last updated: February 2024
This privacy policy (“Policy”) applies to information collected through Adstra, LLC (“Adstra,” “we,” “our,” or “us”) www.adstradata.com (the “Site”).
Introduction
Welcome to the Adstra Privacy Policy. By visiting our Privacy Policy, you’ve taken the first step in educating yourself about advertising businesses, which contribute to the economy’s ability to remain a place where large and small companies can sell products and services affordably through relevant marketing. Additionally, Adstra helps the internet continue to be an ecosystem consisting of free content funded by advertising.
Adstra provides online (e.g., banner advertising) and terrestrial (e.g., traditional direct mail) marketing services. To do this, we follow a privacy methodology that balances the consumer privacy efforts with the need to encourage and support a growing and diverse internet with the utilization of data. This belief structure supports a personalized marketing experience that brings benefits to the consumers through more advance marketing strategies through better personalization and more free publisher content on the internet when done properly.
When you use or visit our Site, we collect the following types of information:
- Personal information you choose to provide to us, for example, when you make requests for information and assistance, such as:
- Your name;
- Mailing address;
- E-mail address; and
- Telephone number.
- Information about the company for which you work.
- Sensitive information, to register for certain products and services.
- Technical information, through our use of cookies, sensors, log files, and other technical mechanisms, such as:
- Browser type;
- IP address;
- Mobile device type and identifier;
- Screen resolution;
- Operating system;
- The date and time of a visit or use;
- The pages visited on the Site; and
- The time spent viewing particular pages of the Site.
To view the Terms of Service for using this Site, please visit https://adstradata.com/terms
By visiting any Adstra website and sharing any information with us, you agree to be bound by this Privacy Policy and the Site’s Terms of Service.
To begin, it is important for you to know two definitions that are key to understanding our services and privacy practices:
Personally Identifiable Information (“PII”): Information that can be linked to a individual person. This type of data includes things like full name, home address, telephone number, or email address.
Non-Personally Identifiable Information (“Non-PII”): Information that cannot identify an individual person, such as an IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.
CONTENTS OF THE PRIVACY POLICY
- Short Form Privacy Policy
- Scope
- What Adstra Does
- Privacy by Design
- Information Collection & Use
- Adstra Does Not Intend to Market to Children
- Information Security
- Self-Regulation and Voluntary Compliance
- Your Choices
- Changes to our Privacy Policy
- Privacy Officer Contact Information
- Your Representations
Short Form Privacy Policy
We have included a table summarizing our practices solely for your convenience and reference purposes. This table is not an exhaustive description of our privacy practices and should not be construed to define, limit, and/or describe the scope or extent of this Privacy Policy. As a result, we encourage you to review the entire Privacy Policy:
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Information Collection: |
We collect PII on behalf of our clients to manage and monetize their data within compliance of the law and voluntary self-regulation. For example, PII may be collected should a marketer wish to send a direct mailer or catalog. Additionally, a consumer may wish to provide PII on his/her own initiative, register with a publisher to download a mobile app, or want to add their information for lead generation purposes with Adstra or its client. |
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Information Collection: Non-PII |
The Non-PII we collect may include, as an example, IP address, browser types, operating systems, domain names, platform type, language preference, access dates and times, referring website addresses, online transactions web browsing, and search activity. |
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How Information is Used |
We may use your PII to mail you an offer to your home address or Non-PII for purposes such as enhancement of our digital services for online marketing, and to more effectively match advertisements, applications, and website content to your interests. |
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Sharing Your Information |
We may share your information with third party service providers with whom we have contracted, our subsidiaries and affiliates, third party marketing partners, business partners and our clients and publishers, as expressly provided for. |
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Your Choices |
You may regulate the collection and use of Non-PII via the opt-out options provided herein or by uninstalling or electing not to install a web browser or mobile application. |
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Security |
We use reasonable and appropriate security measures to protect your data. |
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Retention |
We retain online Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data. We serve as an agent for our clients to manage their first party data and will retain that data based on each of their specific retention policies. |
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Changes |
We may change this Privacy Policy at any time by posting the revised Privacy Policy on the Site along with the date such Privacy Policy was last updated. |
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Contact Us |
If you have any questions about this Privacy Policy, or the practices discussed herein, please contact us at privacy.officer@adstradata.com. |
SCOPE
This Privacy Policy is primarily intended to provide a description of the ways in which we collect and use information to deliver advertising through direct mail and digitally across the Internet. Neither the Sites, nor our online activities or services for our clients, are directed toward or intended for children under the age of 18. We do not collect PII from any person of whom we have actual knowledge is under the age of 18. By using our website, the website of any of our publishers in our networks or submitting information to us, you consent to our use and sharing of the information collected or submitted as described in this Privacy Policy.
Please be aware that in addition to our Sites, the websites of our clients and publishers, applications on which we place advertisements and any third party websites linked to one of our Sites, may also collect information from you for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you. Such information collected by such websites and mobile applications and their affiliated or third party partners may include Non-PII through the use of cookies and other technologies. It may also include any PII you choose to provide in registering and transacting with such websites and mobile applications. Although we choose our business partners and clients carefully, Adstra is not responsible for the privacy practices of websites and mobile applications operated by such third parties. You should check the applicable privacy policies of such websites and mobile applications you visit to determine how they handle any information they collect from you.
WHAT ADSTRA DOES
Adstra operates a data management business for its clients for terrestrial (e.g., direct mail) and digital advertising technology (the “Technology”) enabling marketers to target advertising based upon our proprietary composite of multiple intent signals of users and to recognize devices that you may use to connect to the Internet such as computers, mobile devices, tablets, smart TVs, game consoles and any other device that enables data collection and exchange (all referred to as “Screens”) for the purpose of sequential targeting, interest-based advertising, cross-screen attribution, and optimization of digital advertising. We help advertisers, advertising networks, online merchants and websites (our “Clients”) do a better job at engaging with their customers and prospects (their “Users”). This Privacy Policy covers the data collected by Adstra’s Technology as well as the information collected on www.adstradata.com (the “Website”). Adstra is a member of a number of industry associations that govern the policies around online consumer privacy and digital advertising, including the Digital Advertising Alliance (DAA). We comply with Self-Regulatory Principles for Online Behavioral Advertising (OBA) and Internet Advertising Bureau (IAB).
PRIVACY BY DESIGN
Our philosophy on privacy follows the framework of Privacy by Design. We integrate privacy in strategy, product development, and more. We can protect consumer privacy AND provide relevant advertising, which benefits everyone involved, especially advertisers, consumers, and small business websites and mobile applications. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance, and we are careful to protect privacy as data is collected, used, and destroyed responsibly.
We constantly strive to maintain unparalleled visibility with consumers. We provide transparency and choice through our website, encourage the same practice throughout the Internet, and utilize AdChoices on each banner advertisement and through AppChoices for providing choice and tailoring ads to consumers’ interests. We respect consumer privacy and give consumers the ability to opt out of interest-based advertising (“IBA”).
INFORMATION COLLECTION AND USE
We collect information from your use of our Technology. When you visit any website, mobile site, app or other digital media property where our Technology is enabled (“Client Sites”), we may collect information about your interaction with, and the content on, that Client Site. The information collected via the Technology is put into a “snapshot” and is sent to our servers each time a User visits a Client Site. Our servers use the information to create a unique ID for every Screen that our technology is able to recognize within a reasonable probability. Our Technology uses machine learning to perceive common characteristics between multiple Screens (e.g., common IP address) to infer the likelihood that two Screens belong to the same household. By inferring these types of relationships, we can help our Clients understand how Screens might be related so Clients can deliver advertising and content personalized to their Users based on User interests gathered across multiple Screens. Adstra may use non-PII that it has collected or that it obtains from third parties to create data segments and intent profiles, based upon User interactions with our Clients as well as other User behavior, such as the websites visited and mobile applications used by a User.
Adstra licenses the data collected as described herein to third parties in connection with our business, including to our Clients, our partners and other third parties (collectively our “Business Partners”). This shared information may include non-PII information about your particular Screen (e.g., hardware make and model), its operating system, advertising identifiers (such as Apple IDFA or AAID), IP address, carrier identifiers and other connectivity information, browser version, precise geolocation information, and cookies. This information may be categorized to create audience segments with common interests, intent or other characteristics, but does not include PII. We may also share aggregated, non-PII with our Business Partners, such as aggregated reports derived in part from the information we have collected. The information we share may also be combined with third party data to provide an even broader service to our Clients and Business Partners.
We may disclose information collected from the Website and through the Technology we have if we have a good-faith belief that the disclosure is reasonably necessary to comply with the law, legal process or an enforceable government request; to enforce applicable terms of use for our services; to detect, prevent or otherwise address illegal activity, fraud, or security issues; or to protect the property or safety of our users, Adstra, or the public as required or permitted by law. We may also make both PII and non-PII available to subsidiaries and affiliated companies that are under common ownership or control within the Adstra family.
We may transfer information, including PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Adstra is involved in any such transaction, you will be notified via prominent notice on our Website of any change in ownership or uses of your information, as well as any choices you may have regarding your information.
We also provide information to third parties who provide services to Adstra in connection with operating and maintaining the Website and the Technology. These service providers are prohibited from using the information we provide for purposes other than performing services for Adstra . In addition, we may share aggregated information with Business Partners and the general public, such as usage statistics or demographic trends regarding how you and others may interact with the Website and/or Technology.
INFORMATION SECURITY
The security of your information is important to us. Adstra has implemented reasonable security measures to protect the information, both during transmission and once it is received, including without limitation, use of firewalls, application controls and encryption. No method of electronic storage or transmission over the Internet is 100% secure. So while Adstra strives to use commercially reasonable means to protect your information, we cannot guarantee complete security. If you have any questions about these security practices, please email us at privacy.officer@adstradata.com.
ADSTRA DOES NOT INTEND TO MARKET TO CHILDREN
Adstra’s Website and Technology is designed for people 18 years of age and older. We do not knowingly collect PII from anyone under the age of 13. If we are made aware that we have received PII from someone under the age of 13, we will use reasonable efforts to remove that information from our records.
SELF-REGULATION & VOLUNTARY COMPLIANCE
Our industry has a rigorous voluntary self-regulatory regime, and we are active members of industry groups such as the Interactive Advertising Bureau (IAB), Digital Advertising Alliance (DAA) and Digital Advertising Alliance of Canada (DAAC) who promulgate codes of conduct to which their members must adhere. These codes impose requirements on participating companies such as transparency and choice around the use of data for IBA and require regular audits of member privacy practices.
Adstra is an active member of these and other groups, and where Adstra engages in activities regulated by these programs, we support the DAA Self-Regulatory Principles and the DAAC Self-Regulatory Principles.
YOUR CHOICES
Adstra wants you to be in control of your experience while interacting with the Website and our Technology. We help our Clients provide you with digital advertising that’s meaningful and supports the Client Sites you use for free, so everyone wins. For more information about online behavioral advertising, please visit the DAA website.
Adstra Intent Data Collection Web Browser opt-out: If you’d like to opt-out from web-based targeted advertising from Adstra, please click here. If you’d like to opt-out from online behavioral advertising from any DAA member company, please click here. When you opt-out, our partners, will drop an opt-out cookie that tells our Technology not to deliver targeted advertising to that particular browser or device. If you delete, block, or otherwise restrict cookies, or if you use a different browser or device, you will need to renew your opt-out choice. Please note that you will still see ads if you opt out. The ads delivered through the Technology will just be less relevant to you. We provide you with meaningful choices regarding opt-outs for data collection, including the opt-out links above. However, we do not recognize or respond to browser-initiated Do Not Track (DNT) signals, and we do not control how our Clients respond to DNT.
Adstra Intent Data Collection Mobile Device opt-out: We also honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). For devices where we are able to see that such a selection has been made, we will not use information collected from that device to deliver targeted advertising.
Adstra Cross-Device opt-out: If you’d like to opt-out of cross-device tracking from Adstra we will not share the identity of your device with our Clients for the purpose of enabling online behavioral advertising. Note that we do have some Clients who use our Technology on their own Client Sites, including for things like fraud prevention, which are not subject to opt-out choice. To opt-out of tracking click here.
We may also work with third parties that collect data about your use of the Site and other websites or apps over time for non-advertising purposes. Among these third parties, we may use Google to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
Unsubscribe or Opt Out from Promotional Communications
Adstra offers you the opportunity to opt out of receiving promotional e-mail, calls or mail from Adstra about our products and services. To do so, please click here.
For e-mail, individuals may opt out at any time by using the unsubscribe mechanism within the e-mail, which allows individuals to manage their subscription preferences regarding Adstra newsletters, e-mail alerts and special offers. This mechanism does not allow a user to opt out of receiving transactional e-mail, such as registration confirmation, product updates and responses to direct requests.
Privacy Officer Contact Information
Adstra, LLC
750 College Road East, Suite 201, Princeton, NJ 08540
Email: privacy.officer@adstradata.com
California Privacy Rights
If you are a California resident, the California Consumer Privacy Act (“the CCPA”) provides you with certain rights relating to the data that Adstra may have collected about you. Those rights include:
- The right to opt out of our sale of your personal information.
- The right to know the categories and specific pieces of personal information we may collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information. We use a two-step process to validate identity before providing personal information.
- The right to request that we delete the personal information we may have collected directly from you. We use a two-step process to validate identity prior to deleting information.
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We will not deny, charge different prices for, or provide a different level of services if you choose to exercise these rights.
As described in this Policy, we may make personal information available to third parties for their marketing purposes. California residents may opt-out of Adstra’s disclosure of personal information to third parties for their direct marketing purposes pursuant to California Civil Code section 1798.83 and the California Consumer Privacy Act by clicking here. If you are a California resident and want to know what categories or specific personal information is collected, used, shared or sold about you please click here. If you are a California resident and want us to delete personal information that we may have about you please click here.If you are a California resident and would like to request information we may have about you to be rectified, please click here to submit a request. Once we have verified your identity through our two-step process, we will provide information we may have about you and you may communicate the information you may wish to rectified.
For Colorado, Connecticut, Nevada, Utah and Virginia Residents:
We may make personal information available to third parties for their marketing purposes. Residents from these states may opt-out of Adstra’s disclosure of personal information to third parties for their direct marketing purposes pursuant to their state laws by clicking here. If you want to know what categories or specific personal information is collected, used, shared or sold about you please click here. If you want us to delete personal information that we may have about you please click here. If you would like to request information we may have about you to be rectified, please click here to submit a request. Once we have verified your identity through our two-step process we will provide information we may have about you and you may communicate the information you may wish to rectify.
For Nevada Residents: If you are a Nevada resident and would like to opt-out of the sale of your personal information, please click here, email our Privacy Officer at privacy.officer@adstradata.com, or, send your request to: 750 College Road East, Suite 201, Princeton, NJ 08540.
New Jersey Daniel’s Law
If you are considered a “Covered Person” under Daniel’s Law within the State of New Jersey and wish to request that your address and private phone number not be shared with any third parties for marketing purposes, please click here. Recognizing the essence of Daniel’s Law as a safeguard for covered persons against targeting and the imperative for safety underpinning its creation, Adstra is committed to ensuring these requests are managed appropriately and in strict adherence to legal requirements. Please note that all submissions must go through the link provided above, and any submissions directed to privacy.officer@adstradata.com will be disregarded.
For U.S. Residents:
As described in this Policy, we may make personal information available to third parties for their marketing purposes. U.S. residents may opt-out of Adstra’s disclosure of personal information to third parties for their direct marketing purposes by clicking here. If you are a U.S. resident and would like to make a verifiable consumer request to delete any personal information that we may have about you please click here.
Visitors from the United Kingdom and Europe
If we collected personal information from you and you are a resident of the European Union or the United Kingdom, you have the right to be informed, withdraw consent, or request the deletion/erasure of personal data as defined under the General data Protection Regulation (EU) 2016/679. To make a verifiable consumer request please click here.
Visitors from Canada:
If we collected personal information from you and you are a resident of Canada, you have the right to withdraw consent/opt out, the right to access personal data, or the right of rectification under the privacy policies of your country. To make a verifiable consumer request please click here.
Visitors from Australia:
If we collected personal information from you and you are a resident of Australia, you have the right to withdraw consent/opt out, the right to access personal data, the right of rectification, or the right to request the deletion/de-identification of personal data as defined under the privacy policies of your country. To make a verifiable consumer request please click here.
Verification Process and Required Information. Please note that in order to exercise your rights for information and/or deletion, we may take reasonable steps to verify the identity of a consumer making the request. To prevent the unauthorized access or deletion of personal information, we may request a notarized affidavit verifying a consumer’s identity. We request that our affidavit be notarized and returned to us (as described in instructions that will be provided upon submission request). Adstra will compensate for the reasonable cost of this notarization.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or if an exception applies.
Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests, or a power of attorney. We may also follow up to verify your identity by requesting a notarized affidavit before processing the authorized agent’s request.
Changes to our Privacy Policy
We may modify this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will post the modified Privacy Policy to the Website with an updated “Last Updated” date at the top of the Privacy Policy, and other places we deem appropriate. We reserve the right to modify this Privacy Policy at any time. If you have questions or concerns, you may contact us at: privacy.officer@adstradata.com.
YOUR REPRESENTATIONS
YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose information you supply to us with regard to: (a) the purposes for which such third party’s information has been collected; (b) the intended recipients or categories of recipients of the third party’s information; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.
YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.
