Revised as of April 3, 2018
Ad Server: An ad server, in its simplest form, is responsible for delivering an ad to be shown on a web page. Today, communications may be sent to several servers in the process of selecting and delivering an ad. This occurs in a matter of milliseconds.
Beacons and Tags: Beacons and tags enable online advertising companies to collect data and serve advertising on websites by allowing communication between a web browser and an ad server. A beacon (or web beacon) is a small transparent image that is placed on a web page. A tag is a small piece of computer code that is run by the web browser.
Interest-Based Advertising: Interest-Based Advertising uses information collected across multiple websites to predict users’ preferences and to show ads that are most likely to be of interest to those users. For example, if a user visits a travel site, they might see travel related ads on another site. TouchBase offers web users choices with respect to the use of the Platform for this type of advertising.
PII: Personally Identifiable Information (“PII”) is information that by itself can be used to identify a specific individual. PII includes such things as name, and email address.
Non-PII: Non-Personally Identifiable Information is information that cannot by itself be used to identify an individual person. Non-PII includes such things as browser type, operating system, the web address of a web page visited, the time and date a web page was visited, and the web address of the referring page. It may also include the number of times a particular browser has been shown a particular ad, or it may include generic categories indicating inferences that have been made about users’ interests.
Real-Time Bidding: Advertising buyers are able to bid in “real time” for the opportunity to show an online advertisement when a web page is loaded by a web browser. The winning bidder gets to show their ad on the web page.
The Platform allows our clients to purchase online advertising, including Interest-Based Advertising. The Platform is designed to enable these advertising purposes through the use of non-PII that may be collected by clients using the Platform, or that clients may acquire from other sources. As described in the Privacy Statement below, TouchBase makes certain uses of the PII and non-PII collected by clients on the Platform.
When a user registered with the Platform (“Registered User”) and creates a new account to use the TouchBase services TouchBase will solicit the Registered User’s consent to connect the Registered User’s Google account to the new TouchBase account (using Google’s OAuth authentication method), thereby providing TouchBase with access to the Registered User’s Gmail and Google Plus profiles, email and Contacts.
When a Registered User signs into TouchBase using Google OAuth, the following permissions, or scopes, are required.
- https://www.googleapis.com/auth/userinfo.email is used by My App to create a user account for the Registered User.
- https://www.googleapis.com/auth/userinfo.profile is used by My App to assist in account creation and login to the App.
- https://www.googleapis.com/auth/gmail.readonly is used by My App to view the Registered User's email headers in order to get the email recipients and the date contacted, which allows the Application to determine which contacts to show the digital business card to. This is the core function of the App. The Application does not save any details from the email message, other than the recipients’ emails and the date when the message was sent.
- https://www.googleapis.com/auth/plus.me is used by My App to prefill a digital business card in My App with the Registered User’s name and photo (if available).
As a Registered User uses and accesses TouchBase for Gmail, TouchBase will learn certain information about the Registered User. How TouchBase will handle information TouchBase learns about a Registered User depends upon how the Registered User uses the product.
- The name of the domain from which a Registered User accesses the Internet
- Which browser a Registered User uses to connect to our service
- The Registered User’s browser history, which allows TouchBase to only appear in Gmail
- The date and time a user accessed the service
- Email address, which is used to create the TouchBase account.
- A Registered User’s Google Plus profile is used to help determine data to prefill an in app form with, to increase the quality of the user experience.
- Email message headers (message subjects and bodies are not stored) for email messages. This allows TouchBase to automatically create and maintain a contact list for the user.
- The Platform uses unique cookies to identify web browsers and to store data for advertising purposes, including Interest-Based Advertising.
- The Platform uses unique cookies to store ad delivery and reporting data, such as, for example, which ad was shown, the number of times a particular ad has been shown, and how recently an ad has been shown to a particular web browser.
- The Platform uses unique cookies to track users’ responses (clicks and conversions) to ads purchased on the platform.
- The Platform uses non-unique cookies for server load-balancing and similar technical purposes.
- The Platform uses non-unique cookies to store users’ opt-out choices.
- The Platform is designed to use non-PII only.
Collection and Use of Information
What information do we collect and use?
PII: The Platform does not collect PII, and TouchBase prohibits clients from collecting PII on the Platform. The Platform may use PII provided by customers for purposes of targeted advertising and providing services requested by the customer, but any such PII is converted to anonymized data before it is used by the Platform, is only used as anonymized data, and is not stored or transferred to third parties as PII.
Non-PII: TouchBase collects and uses non-PII collected on the Platform.
How do we collect information?
- TouchBase also receives non-PII from data vendors in connection with the Platform.
For what purposes do we use the information?
- TouchBase uses the information collected on the Platform to provide, operate, manage, maintain, and enhance the Platform.
- TouchBase may act as a client of the Platform to engage in its own online advertising of its business.
- The Platform enables TouchBase’s clients to use non-PII they collect to buy online advertising, including Interest-Based Advertising.
- Particular advertising-related purposes for which TouchBase clients may use the non-PII they collect on the platform include:
o Interest-Based Advertising (Users can opt out of Interest-Based Advertising through a number of channels, including TRUSTe’s Ad Choices, the Network Advertising Initiative’s Consumer Opt-Out Page, and the Digital Advertising Industry’s opt-out platform).
- Limiting the number of times a user sees a particular ad.
- Showing ads in a particular sequence.
- Customizing ads to a particular geographic region.
- Showing ads related to the content of the web page on which they are shown.
- Determining when users respond to ads.
- Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns.
What information does TouchBase share with third parties?
TouchBase may, to operate or enhance TouchBase’s services, provide data collected on the Platform to clients, corporate customers, and service providers. For corporate customers that are participating in TouchBase through a sponsored corporate customer program, TouchBase will share data collected on the Platform (including, for example, lists of the clients participating in the corporate customer program and information about their campaigns) with the sponsoring corporate customer. In addition, TouchBase may disclose such information in the event we reasonably suspect malicious activity or believe that we are legally required to do so. TouchBase may also share aggregated data derived from the Platform, including, for example, statistics about Platform activity. Finally, we may transfer Platform data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
How is the information stored and how long is it kept?
TouchBase uses generally accepted industry security standards to store Platform data.
Non-PII stored in the Platform is retained in the Platform in non-aggregated form for up to 12 months. Aggregated data is used for reporting and analysis, and may be stored in the Platform for up to 2 additional years.
What happens if this privacy statement is changed?
If you have questions about privacy on the TouchBase Platform, you may email us at firstname.lastname@example.org.
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