Product Privacy Policy

Updated: August 12, 2020

About Traverse

Traverse Data, Inc. (“Traverse,” “We,” “Us,” “Our”)  is a data-driven service provider that delivers secure data licensing, matching, distribution, activation, and monetization solutions to the digital ecosystem.

Our aim is to help our publisher clients supplement their advertising revenue, while providing our business partners with the means to offer more accurate cross-device products to their customers. As a result, the market will see enhanced targeted display advertisements, send more relevant email offers, and craft accurate marketing attribution models.

What Does This Privacy Policy Cover?

This privacy policy (“Policy”) describes how we collect, use and share data solely in connection with our products and services (“Products”), including the information we receive from our Data Partners and Clients. These include brand marketers, online and mobile advertising partners, email marketing companies, and online publishers engage relevant consumers across a variety of contexts. This Policy does not apply to information we collect and use on our corporate website, located at www.traversedata.com. Please see our Website Privacy Policy for information on our privacy practices as they relate to our company and website. Additionally, the collection of information by our Data Partners and Clients and their use and disclosure of such information is subject to their own individual privacy policies.

Traverse’s Commitments and Adherence

Traverse supports initiatives of greater transparency, privacy and control for users and adheres to comply with the following industry self-regulatory efforts.

  • The Digital Advertising Alliance. Traverse adheres to the Self-Regulatory Principles for Online Behavioral Advertising set forth by the U.S.-based Digital Advertising Alliance (“DAA”). Traverse clients subscribe to the DAA opt-out platform which offers U.S. consumers choices to opt-out from behavioral (interest-based) advertising. For more information please follow this link to www.AboutAds.info
  • The Data & Marketing Association. Traverse adheres to the Guidelines for Ethical Business Practice set forth by the U.S.-based Data & Marketing Association (“DMA”). Traverse and our marketer clients honor consumer choices relating to the email marketing offers they may receive. Please visit the DMA for more information about their self-regulatory program.

Quick Reference

Key Terms
Traverse Products Overview
Types of Information We Collect
How We Use the Information We Collect
Your Choices
Access and Managing Personal Information
Data Security
Children
Changes and Updates to This Privacy Policy
Contacting Traverse

Key Terms

Prior to learning about Traverse’s privacy practices, it may be helpful to familiarize yourself with some of the key terminology we use when describing the technology and processes surrounding Traverse’s data services. We’ve prepared a helpful glossary for you here. Any terms not defined in this policy will have the meaning provided in this glossary.

Traverse Products Overview

Traverse Products utilize pixel tags (aka; web beacons), cookies and similar technologies to synchronize information between our Clients and Data Partners in the digital ecosystem. This synchronization process allows Traverse clients to supplement website or mobile advertising revenue, enhance targeted display advertisements across websites, send more relevant email offers, engage in people-based marketing and perform marketing attribution analysis.

Traverse acts as a data matching and pass-through service provider on behalf of our Clients who purchase our products and services for their use. We do not have a direct relationship with consumers or other end users, as we work solely in coordination with publishers, data management companies, marketing technology platforms, advertisers and marketers. This Privacy Policy describes our collection and use of various types of information we utilize and license on behalf of these Clients and Data Partners to assist them in their disclosure obligations to their end users on the Client’s or Data Partner’s website or mobile application, as applicable.

Types of Information We Collect

We receive data hashed personal and other non-personal information from our Clients and Data Partners through various offline and online sources. We do not intentionally collect or receive information that is deemed by U.S. law to be personally identifiable that is not in a hashed format, such as name, postal address, phone number or email address.

Traverse (or our partners on our behalf) collect the following data to be used in our various marketing related products and services: (1) hashed data derived from email addresses or other previously personal information; (2) website visitor data (including mobile websites) collected via placement of cookies; and (3) mobile device identifiers (Apple ID, Google Ad ID) through select Data Partners who enable such information sharing, and other data which helps us link the various data points we need to deliver our Products.

Information Collection

Through the implementation of Traverse pixel tags and other technologies that our Clients or Data Partners place on their digital properties, such as standard and mobile websites, Traverse collects hashed email addresses and places a cookie on the user’s browser, or collects a unique identifier from your mobile device. The type of information collected through the placement of the pixel may include other commonly associated information from your device or Internet access, such as your IP address, as well as attributes that are unique to the website you visited, ad you viewed, or marketing email you interacted with. These unique attributes help us and our partners link a hashed email to other unique non-personal identifiers.

A Traverse cookie contains a unique number (“Traverse ID”) which is used by Traverse to recognize your browser when you visit another website. Traverse sets and uses these cookies to collect information about which websites you visit, and synchronize this activity with our Data Partners. As described above, when you register and volunteer your email address on a Client or Data Partner website, Traverse may synchronize your hashed email address with other unique information about the websites you may have visited.

Cross-Device Collection

In order to help our Clients facilitate the most relevant ads possible, Traverse works with various advertising networks who assist with delivering similar ads to users across devices including computers, tablets, and smartphones. Traverse or these advertising networks may attempt to synchronize the hashed email address or the Traverse ID with IDs collected from other data partners, such as cookie IDs from third party domains. As an example, if you see an ad that Traverse helped facilitate on your computer web browser, you may see a similar ad on a mobile website or mobile application, or within an email offer, facilitated through cross-device and cross-channel synchronization processes. See below for more information on how we use this information and your choices for continued tracking.

Information Received from Other Third Party Sources

In addition to data collected through our Data Partners and Clients, from time to time Traverse may work with other data brokers to supplement or append unique user and other non-personal data to our Products. This may include unique user data that is synchronized with third party data providers, inferred data based on interest-categories, or aggregated information. Examples of appended information may include demographics such as gender, age, marital status, regional census data, and income or psychographics such as lifestyle interests. In any case, Traverse does not intentionally collect or receive any information that may be deemed ‘sensitive’, such as protected health information or credit-worthiness.

How We Use the Information We Collect

Our core business is linking, synchronizing, aggregating, sharing and licensing hashed personal and non-personal information with our Clients and Data Partners. We do not currently provide hosted or managed data services on behalf of these partners, but rather pass-through the synchronized information for use by these partners. Additionally, we do not select ad placements or deliver any ads or email offers directly to you.

For Traverse Products to be used, we need to synchronize our hashed information and IDs with other parties who then select and facilitate ad delivery to web, email or mobile users. Our synchronization process involves matching a Traverse ID to a publisher’s own unique ID during an active web, email or mobile experience. For example, when you visit a Traverse Data Partner website and the Traverse cookie (with a Traverse ID) is created, Traverse may immediately ‘call’, or be called from, another service provider to drop another cookie (with another ID), and to synchronize these IDs such so that the user’s identity is not known to us or is otherwise inappropriately re-identifiable. Our advertiser and publisher clients may then work with various advertising networks and email marketing companies to deliver relevant advertising through such platforms, including but not limited to by matching Traverse’s hashed information with non-hashed information stored by the advertiser or publisher client, or provided by third party advertising networks or email marketing companies. Please see the “Your Choices” section below if you do not wish to receive such targeted offers.

We may in good faith also share information (a) as required by law, such as to comply with a subpoena or other legal process or government reporting obligations, or (b) with affiliates, service providers, advisors, and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets. We may also share your data when we believe that disclosure is necessary to (c) protect our rights or the integrity of our business and Products, or (d) your safety or the safety of others.

We may combine, aggregate and share any of the information we collect through our Products for any of these purposes.

Your Choices

You have many options to block, delete or opt-out of Traverse’s tracking methods. In every contemporary Internet browser you may elect to refuse third-party cookies such as Traverse’s, or delete cookies altogether. However, should you block or delete third-party cookies such as Traverse (or those of our Data Partners or Clients), you will continue to receive online advertisements and those advertisements may be less relevant to you.

Cookies have an expiration date, and Traverse has set ours to expire in one (1) year. However, this expiration is contingent upon not ‘seeing’ that cookie again during that one-year period. Should you visit a Traverse Data Partner or Client prior to the one-year period being complete, your existing Traverse cookie may be updated with a new one-year expiration date. Please note that at the current time, we retain collected data for as long as it is necessary to maintain the efficacy of our products.

Use the button below to opt-out from Traverse’s data collection on this browser.

You may use the button below to opt out of Traverse's data collection on your current browser.

Opt out.

Interest-Based (aka; Behavioral) Ads

In addition to browser or mobile controls, you may choose to opt-out of industry-wide Interest-Based Advertising by using the Digital Advertising Alliance’s opt-out platform.

Mobile Ads

For mobile users, you also have numerous controls in your Operating System that enable you to choose whether to allow cookies, or share your advertising ID (such as the Apple ID or Google Ad ID) with companies like Traverse or our Data Partners. For more information on controlling your mobile choices, click here; http://www.networkadvertising.org/mobile-choices. To help control or block certain ads in mobile applications, you may choose to download and utilize the DAA’s AppChoices mobile app.

Email Marketing and Linkage

If you wish to restrict Traverse pixel tags or cookies from being associated with marketing emails from Traverse Clients, you may do so at any time by following the instructions above to opt-out of Traverse cookies, or by clicking the “Unsubscribe” links at the bottom of the email message,

If you wish for your email address to be removed from any association with Traverse Products, please email us at [email protected] using the same email address you wish to remove. Please include the nature of your request in the subject line of the email. We will cease synchronizing your hashed email address (and any associated IDs) with our Clients and Data Partners. We may, however, continue to use this information for research and development purposes only, unless you are a California resident, in which case the opt out provisions below shall apply to your information.

Access and Managing Personal Information

As noted, Traverse does not interact directly with consumers. We do not intentionally collect or share any information that is not in hashed format. Therefore, except as otherwise specified in this Privacy Policy, it is generally not feasible for us to provide you with access to, or the ability to manage, your personal information.

California Privacy Disclosures

This section provides additional details about the personal information we collect about California residents and the rights they have under California law.

California Consumer Privacy Protection Act

To find out more about the personal information we have collected over the last 12 months, including the categories of sources, please see the Types of Information We Collect section above. We collect this information for the business and commercial purposes described in the How We Use the Information We Collect section above, including by selling personal information to our Clients and Data Partners (please see below on how to opt-out of the sale of your personal information). We do not intentionally collect the personal information of California residents under the age of 16 and do not have actual knowledge that we have sold any such information.

The types of personal information we have sold to our Clients and Data Partners during the preceding 12 months include identifiers (online identifier, internet protocol address, hashed email address), Internet or other electronic network activity information (information regarding your interaction with an internet website, application, email, or advertisement), and inferences about you drawn from this information.

The types of personal information have disclosed for our business purposes during the preceding 12 months include identifiers (unique personal identifier or online identifier), Internet or other electronic network activity information (information regarding your interaction with an internet website, application, email, or advertisement), and inferences about you drawn from this information.

Under California law, California residents have the right to request that we disclose what personal information we collect, use, disclose, and sell. If you are a California resident, upon receipt of a verifiable request we will provide you with the specific pieces and categories of personal information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. Under certain circumstances, California residents also have the right to request that we delete their personal information.

To submit a request to know, request to delete, or request to opt-out, please either submit through this webform or call +1 (800) 357-7078. If you choose to exercise your right to know, delete, or opt-out under California law, we will not treat you differently from any other user unless those differences are related to your information.

In order to verify your request to know or delete information, we may require you to provide us with your first name, last name, and email address. We may also require you to take certain actions, such as clicking on a verification link sent to your email address, or to provide us or our authorized agent with certain information to be used solely for the purpose of verifying your identity. You may designate an authorized agent to make a request on your behalf. You may designate an authorized agent to make a request on your behalf, provided that we are provided with a valid power of attorney and are able to verify the identity of the authorized agent.

Shine the Light

Under California law, California residents who have an established business relationship with a company may choose to opt out of that company sharing their personal information with third parties for direct marketing purposes. If you are a California resident and you wish to request certain information regarding our disclosure of your PII to third parties for the direct marketing purposes, please send an e-mail to [email protected] with “California Third Party Disclosure” in the subject line, or contact us as set forth in the “Contacting Traverse” section below.

Record Keeping Obligations

Pursuant to Section 999.317(g) of the California Consumer Protection Act, the Traverse received and responded to requests made by all individuals (including California consumers) during the 2020 calendar year as follows:

Type of Request

Number of Requests Received

Number of Requests Compiled With (in Whole or in Part)

Number of Requests Denied

To Know

16

12

4

To Delete

14

14

0

To Opt-out

19

19

0


During the 2020 calendar year:

  • The mean number of days within which Traverse substantively responded to a request to know was 18 days;
  • The mean number of days within which Traverse substantively responded to a request to delete was 16 days; and
  • The mean number of days within which Traverse substantively responded to a request to opt-out was 6 days

Data Security

The security of your personal information is important to us. We use commercially reasonable security measures to protect your Information, both during transmission and once we receive it. Although we work hard to ensure the integrity and security of our information systems, no method of transmission or safeguard is 100% immune. Therefore we cannot guarantee the security of your Information.

We will retain your personal information for the length of time needed to fulfill the purposes outlined in the Privacy Policy and our Product Privacy Policy. We will not keep non-aggregated Information for longer than one (1) year unless a longer retention period is required, requested contractually by our clients, or is required or permitted by law.

Children

Traverse Products do not intentionally collect the information about individuals under the age of sixteen (16). We work with our Clients and Data Partners, and implement contractual controls, to prevent our receipt of such personal information. If we become aware that a child under 16 has provided us with personal information, then we will delete this information from our files. Please send an email to [email protected] or call +1 (800) 357-7078 to have a child’s information deleted.

Changes and Updates to this Privacy Policy

We may revise our Product Privacy Policy from time to time. If we make any significant changes our privacy practices, or revise this Privacy Policy, we will post those changes to our Site and other places we deem appropriate so that you are aware of such changes. You can see when the last update was by looking at the “Last Updated” data at the top of this page.

Contacting Traverse

If you have any questions or concerns about our collection, use, or disclosure of your personal information, please email is at [email protected], or, please write to us at:

Privacy
Traverse Data, Inc.
113 Cherry Street #66016
Seattle, WA 98104

Open

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