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Retired Crosswise Privacy Policy

Note: this privacy policy was retired on June 1, 2017 and replaced with the Oracle Marketing Cloud and Oracle Data Cloud Privacy Policy. Click here to view that policy.

Crosswise Privacy Policy

Welcome to Crosswise.com, a website owned and controlled by Crosswise, Ltd. (“Crosswise”, “we”, “us”, or “our”). We provide this privacy policy (the “Privacy Policy”) to let you know what information we collect, how we use it, share it and protect it. We participate in the Digital Advertising Alliance (DAA) and self-regulatory programs and adhere to the DAA Principles for Online Behavioral Advertising as they apply to our activities. Click here to learn more about the DAA.

1. SCOPE

This Privacy Policy describes how Crosswise collects and uses information collected by means of our website located at www.crosswise.com (the “Site”) and in connection with the services (the “Services”) we provide. Our Services include providing data services to clients such as DSPs, retargeters, DMPs, attribution providers, analytics companies and other businesses (the “Customers”) to help our Customers understand information about their customers or third parties (the “Users”). We use data received from Customers and other third parties, as well as machine learning and proprietary algorithms to suggest likely connections between devices, such as smart phones, computers, tablets and connected TVs (the “Devices”).We want to make sure you understand what we do and how we do it so that you can make informed decisions about how your data is used. Our privacy policy below describes what information we receive in respect of Users and Devices and other information we receive and how we use it. Our Customers may use the information we provide to them to deliver targeted or online behavioral advertising to you as well as for other purposes. Please note that different web browsers have independent identifiers. So too, mobile devices and web browsers operate with different identifiers (even though they may be on the same Device). This is the reason that you will need to opt-out of each environment separately.

• Web browser opt-out: If you prefer that we do not include information regarding your Device’s browser in results we provide to our Customers (the “Results”), click below to opt-out. Please note that this opt-out must be performed separately for each browser on each Device. When you opt out, we will place a cookie on your Device, if it supports cookies. Please note that if you block cookies, our opt-out process may not function properly. Please also note that if you delete, block, or otherwise restrict cookies, or if you use a different computer, Device or Internet browser, you will need to renew your opt-out choice.
• Mobile Device opt-out: You may also opt-out by entering your Apple IDFA or Android Advertising ID below. This option must be performed manually. We will then remove your ID from the Results we provide to our Customers.
• Click here to opt-out.

2. INFORMATION WE COLLECT, HOW WE USE INFORMATION

This Privacy Policy describes how we collect and use Personal Information and Non-Personally Identifiable Information. “Personal Information” is information that may be used to identify or locate an individual, like a person’s full name, postal address, e-mail address, or phone number, as well as other non-public information that is associated with this Personal Information. “Non-Personally Identifiable Information” is information that is not used nor intended to be used to personally identify an individual and is not associated with nor linked to Personal Information. The Non-Personally Identifiable Information we collect via the Site includes your Internet Protocol address, device identifier, browser type, browser language, the date and time of your request, and the web page you have visited immediately prior to visiting the Site.

1. Our Website. We created our Site mainly to tell Clients and prospective Clients about us and our Services. We do not provide Services by means of our Site. We do not instruct you to provide personally identifiable information by means of the Site.

• Personal Information. Personal Information is collected when you access our Site only when you knowingly provide it, for example when you provide feedback, or request information using the “Contact Us” link. Personal Information collected by means of the Site is used to send communications and administrative emails, to respond to your inquiries, and to send marketing and product update messages to those who ask for such messages.
• Non-Personally Identifiable Information. We collect Non-Personally Identifiable Information automatically when you visit our Site. This Non-Personally Identifiable Information we collect via the Site can include your Internet Protocol address, device identifier, browser type, browser language, the date and time of your request, and the web page you have visited immediately prior to visiting the Site. Non-Personally Identifiable Information collected by means of our Site is used internally, for example, to help diagnose problems with our servers or to make our Site more useful.

2. Our Services. We use Non-Personally Identifiable Information which we receive in respect of Users in order to suggest likely connections between Users’ Devices. We receive the following information with respect to Users by means such as cookie-sync:

• The page a User has requested or the application the User is using
• The date and time the User has visited the page or used the application
• The device internet protocol (IP) address
• Mobile device identifier (such as Apple IDFA or Android Advertising ID)
• Geo-location (including truncated GPS coordinates)
• Data that can be extrapolated from an IP address (such as the country or city in which a User is located or demographic data with respect to the User)
• User agent string that specifies device and browser information
• Carrier
• Referring/exit pages
• Gender
• Age
• Cookie information (e.g. a unique device identifier, stored in a browser cookie)
• An obfuscated or hashed user identifier, such as email address or user name, which we only use in order to evaluate the probability and nature of connections between Devices, never to identify the individual.

3. We do NOT ask to receive Personal Information, such as the following, and we do not require Personal Information, such as the following, in order to generate Results which we provide to our Customers:

• Name
• Address
• Phone number
• Website or application password
• Precise location

However we do not control whether we are provided with this type of data.

3. INFORMATION SHARING

1. With Customers. We use information in order to generate the Results which we provide to our Customers. We do not incorporate Personal Information in Results we provide to our Customers, and our Results only determine the probability that Devices belong to the same User. Our Results identify Devices by device identifier and communicate to our Customers that, based on the information available to us, it is likely that these Devices are used by the same individual. Our Results do not link Devices to particular individuals by use of names, addresses or other personally identifying information. While we include in our agreements with our Customers contractual provisions which govern use of Results, we do not control how Customers use Results; and our Customers’ collection and use of Results is governed by their own privacy policies. If you have questions about how our Customers collect and use Personal Information or Non-Personally Identifiable Information, please be in touch directly with our Customers. Our Customers may use our Services and Results in connection with the following as well as other activities:

• Fraud prevention
• Targeting or behavioral advertising
• Frequency capping (i.e. not showing a User an ad if a certain number of ads has already been shown)
• Attribution (i.e. performance measurement)
• Analytics
• Translating an advertising segment from desktop Devices to their corresponding mobile Devices or the other way around

2. With Other Third Parties. We may share Personal Information and Non-Personally Identifiable Information collected via the Site or received in connection with our Services with other companies or individuals as follows:

• Third party vendors or service providers, such as vendors that assist us in sending emails, or with marketing and customer service, or third parties who provide us with other services in connection with our business.
• With third parties if we have a good faith belief that access, use, or disclosure of such information is reasonably necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) detect, prevent, or otherwise address fraud, security or technical issues, or (c) protect against harm to the rights, interests, property or safety of Crosswise, its users or the public as required or permitted by law or to enforce our agreements.
• With any of our affiliates, subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy.
• With third parties to whom you ask us to send Personal Information;
• In the event we go through a business transition such as a merger, consolidation, bankruptcy, acquisition by another company, or sale of all or a portion of our business or assets, Personal Information and Non-Personally Identifiable information may be among the assets transferred.

3. In addition, we may aggregate your Non-Personally Identifiable Information with the Non-Personally-Identifiable Information of others and share that aggregated information with third parties on commercial terms that we can determine in our sole discretion without restriction. Please note that the parties and individuals listed above may be located in countries other than your own, and we may send them information we receive. All such parties will be subject to non-disclosure and non-use obligations. Nevertheless, some countries may have levels of protection of personal and other information which are not as high as in your country of residence or business.

4. COOKIES

We use Cookies on our Site and Services. “Cookies” are small pieces of information that a website sends to your computer’s web browser while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed or blocked by following the help file directions in your Internet browser. We also use log files and Cookies to improve the quality of our Site and Services; to keep track of your login name, passwords, and pages you have visited on the Site; and to tailor content to your interests and to personalize the Site on your behalf.

5. INFORMATION SECURITY, RETENTION, AND DATA INTEGRITY

We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. We restrict access to Personal Information to Crosswise employees, contractors and agents who need to know that information in order to operate, develop or improve our Site and Services. These individuals are bound by confidentiality obligations and may be subject to penalties, including termination, if they fail to meet these obligations. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances. We retain Personal Information received from the Site and de-identified or aggregated data indefinitely. We retain Non-Personally Identifiable Information for up to one year. Crosswise processes information in a way that is compatible with and relevant for the purpose for which it was collected.

6. ACCESS

Crosswise will allow an individual access to his or her Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. To request such access, or correct, update, or amend your personal information please contact us at the following email address: support@crosswise.com

7. CHILDREN

We do not knowingly collect or maintain Personal Information from individuals who are under 13 years of age, and no part of our Site or Services are designed to attract people under the age of 13. Protecting the privacy of children is very important to us. If we obtain knowledge that a User is under the age of 13, we will take steps to remove that User’s Personal Information from our databases.

8. LINKS TO OTHER SITES

Our Site may contain links to, and allow you to share content on, third party websites and services. The fact that we link to a website or service or allow you to share content on them is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. Other websites and services follow different rules regarding the use or disclosure of the personal information. We encourage you to read the privacy policies or statements of the other websites you visit.Your Personal Information and Non-Personally Identifiable Information may be processed or used in jurisdictions with laws or regulations governing personal data collection, use, and disclosure that differ from those of the jurisdiction in which you reside. Please be advised that through your continued use of the Site or Services, you are transferring your Personal Information and Non-Personally Identifiable Information as described above and you consent to that transfer. Additionally, you understand that your Personal Information may be processed in countries where laws regarding processing Personal Information and Non-Personally Identifiable Information may be less stringent than in your country.

9. CHANGES TO THIS PRIVACY POLICY

Please note that this Privacy Policy may change from time to time. If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this Site or by writing to us at the email address set forth above.

10. ENFORCEMENT, QUESTIONS, AND COMPLAINTS

Crosswise regularly reviews its compliance with this Privacy Policy. Crosswise commits to resolve complaints about your privacy and our collection or use of your Personal Information. If you have questions or complaints regarding this privacy policy should first contact Crosswise by emailing us at support@crosswise.com.

Our address is:
Crosswise Ltd.
115 Ha-Hashmonaim
Tel Aviv, Israel

Last Updated: March 2015