Traverse

Privacy Policy

+ Onboarding
+ Attribution
+ Personalization
+ Cross-Device Targeting

Privacy Notice

This Privacy Notice describes how Traverse LLC ("Traverse," "we," "us," "our") collects, uses, and shares the information collected through our technology and service (our "Service").

About Our Service

Traverse is a specialized data licensing agency; we license data to our clients, which allows them to customize their website or mobile applications, display personalized advertisements, link multiple devices to the same unique user, and perform marketing attribution analysis. By using our Service, our clients are able to serve more personalized and relevant ads.

What Type of Information Do We Collect?

We collect non-personally identifiable information ("non-PII"), and we may also collect personally identifiable information ("PII") about you. Throughout this Privacy Notice, we refer collectively to non-PII and PII as your "Information." PII is any information that can be used to individually identify you, such as your name, email address, postal address, and/or telephone number. The non-PII we may collect includes, but is not limited to, (i) your interactions with web-pages and our Services; and (ii) demographic and interest data, such as age range; gender; marital status; language you speak; education level; occupation; purchase intent; the country, city or zip code in which you reside; device information about your computer, mobile phone or other device, including IP address, unique device identifiers, advertising IDs, browser type, browser language, and other transactional information; and anonymized PII, such as a one-way hashed email address.

How Do We Collect Your Information?

We collect your Information through our Service via cookies, beacons, tags and other tracking technologies. We also collect your information from third parties. When we receive your Information from third parties, we use commercially reasonable efforts to ensure that these third parties have the right to share your Information with us, and that they follow applicable laws and industry codes and guidelines with respect to data collection, use and sharing.

Collection Through Our Service via Cookies, Beacons, Tags and Other Tracking Technologies

Our Service uses session and persistent "cookies", which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions.

Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your web browser to decline cookies, some features of the website and/or online services that you are using may not work or may not work as designed. To learn more about cookies generally, and how to disable them, the Interactive Advertising Bureau provides more information at http://www.allaboutcookies.org.

We may also use pixels, web beacons and other tracking technology. A web beacon is an invisible graphic on a web page that is programmed to collect non-PII about your use of a given website. We may also collect Information from your browser that may enable us to track your device across unaffiliated websites for security purposes related to our advertising services (e.g., click fraud prevention).

Your browser or device may include "Do Not Track" functionality. We do not monitor, recognize or honor any behavioral advertising opt-out or do not track mechanisms, including general web browser "Do Not Track" functionality.

Third Party Analytics

We may use third-party analytics services (such as Google Analytics, Amazon Web Services, and Kibana) to evaluate your use of the Service, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Service and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Service, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out herein. For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics.

How Do We Use and Share Your Information?

We use your Information to provide, operate, manage, maintain and enhance our Service. We may aggregate your Information with other information and use it for reporting, research and analysis purposes.

Our Clients

Through our Service, we license your Information to our clients, which allows them to customize their websites or mobile applications, display personalized advertisements, and perform marketing attribution analysis. Our clients' use of your Information, after we share it with them, is subject to their own privacy practices and policies and not subject to this Privacy Notice. You can find the privacy policy of one such client, Criteo Corp., here http://www.criteo.com/privacy/

Third-Party Service Providers

Certain third parties perform service functions on our behalf, including, but not limited to, marketing and analytics. These entities may have access to your Information, if necessary to perform their functions. If such access is required, we use commercially reasonable efforts to contractually obligate these third parties to only use your Information as necessary to provide us with their services.

Assignment and Transfers

We may change our ownership or corporate organization, or sell certain assets associated with the company and the Service. As a result, please be aware that in such event we may transfer some or all of your Information to an entity acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would use commercially reasonable efforts to require the acquiring party to follow the practices described in this Privacy Notice, but we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Notice.

Law Enforcement, Legal Process, and Emergency Situations

We may also use or disclose your Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with valid legal process; (b) protect and defend our rights or property, the Service or our clients, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, our clients, or the public.

How to Opt-Out of Certain Data Collection and Sharing

You can opt-out of interest-based advertising (or, in other words, having the Service used to select ads for your browser based on your online web browsing behavior). A few things to keep in mind regarding opting-out:

  • When you do this, a third party opt-out cookie will be stored in your web browser. The Service will know the choice you have made when it sees your opt-out cookie, and will apply your choice to all clients' use of the Service. If you block or delete the opt-out cookie, the Service will not see your choice. Please note that the opt-out cookie may not work if your browser is configured to block third-party cookies.
  • If you delete your cookies, you will need to opt-out again. Please visit http://www.aboutads.info/pmc information regarding browser plugins to help you preserve your opt-out cookies.
  • The opt-out only applies to the browser in which you set it. For example, if you set the opt-out while using Firefox, but then use Chrome, the opt-out will not be active in Chrome. To out-out in Chrome, you will need to repeat the opt-out process.
  • The opt-out does not block or delete cookies, or prevent the use of cookies or other technologies for purposes other than selecting ads based on your interests as inferred by your online web browsing behavior. If you opt-out, Information may still be collected about your web browsing activities and you will still see advertising. Ads may be selected, for example, based on the content of the web page in which they are shown.
  • To learn more about interest-based advertising, visit the National Advertising Initiative's opt-out page at http://www.networkadvertising.org/choices/.

Mobile device system software such as Apple iOS or Google Play Services provide an opt-out choice that will be communicated to companies providing in-app advertisements. For more information, go to:
    Apple: http://support.apple.com/kb/HT4228
    Android: http://www.google.com/policies/technologies/ads/

Security & Retention

We use commercially reasonable security measures to protect your Information, both during transmission and once we receive it. This includes the use of encryption or hashing of your PII. No method of transmission over the Internet or method of electronic storage is 100% secure, however; therefore we cannot guarantee the absolute security of your Information.

The time period for which we keep your Information varies according to how it is used. We will retain your Information as long as necessary for the purposes for which it was collected or for which it is to be further used, but in no event will we keep non-aggregated Information for longer than [two years].

Industry Self-Regulation

We are committed to complying with the Digital Advertising Alliance's Self-Regulatory Program for Online Behavioral Advertising and the Network Advertising Initiative's Self-Regulatory Code of Conduct.

Other Important Information

Notice to Non-US Users

It is important to note that Traverse and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information will be transferred to the United States. By using or otherwise interacting with the Service, you hereby irrevocably consent to this transfer and our use of the Information and data provided by you in accordance with this Privacy Notice.

Children's Information

We do not knowingly collect personal information from children under 13 years of age. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Notice by instructing their children to never provide PII through the Internet without their permission. If you have reason to believe that a child under the age of 13 has provided PII to us, please contact us, and we will endeavor to delete that information from our databases.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with a company may choose to opt out of that company sharing their PII with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) 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 privacy@traversedlp.com with "California Third Party Disclosure" in the subject line.

Third Party Websites

We have no control over the privacy practices or the content of any third party websites to which we provide links or which may link to us. This includes websites that are owned or operated by our clients, business partners, advertisers, sponsors, or other third parties. As such, we are not responsible for the privacy practices or the content of those third-party websites. You should check the applicable third-party privacy notice and terms of use when visiting any other websites.

Changes in Our Privacy Practices

We may change this Privacy Notice from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.

How to Contact Us

If you have any questions regarding this Privacy Notice or our privacy practices, please contact us by email at privacy@traversedlp.com, or, by regular mail at Traverse, LLC, 52 Sherwood Drive, Larchmont, NY 10538.

Last updated: February 1, 2016