This policy applies whenever Oracle facilitates the collection and flow of information about you from one data provider, customer, or partner to another for interest-based advertising purposes using Oracle Marketing Cloud and Oracle Data Cloud services. This is known as "third-party" information, and includes both information that does not identify you and as well as information that does. The section of this policy entitled "Types of Information Collected" describes these different types of information.
This policy applies to third-party information used in the Oracle Marketing Cloud and Oracle Data Cloud for interest-based advertising that is collected from any source or device, whether laptop or mobile device, browser or application. The process and technology used when interacting with mobile devices is described throughout this policy and is the same process and technology used for other contexts.
Interest-based advertising is advertising served to the users of computers and other electronic devices that is tailored based on their interests, usage patterns and behaviors. Companies use the Oracle Marketing Cloud and Oracle Data Cloud for interest-based advertising to try to make the content and ads that you see more relevant to you based on information that has been collected by Oracle and Oracle customers, data providers and partners.
When using Oracle Marketing Cloud and Oracle Data Cloud services for interest-based advertising, our customers, data providers and partners share, collect, store and process information about individuals as well as attributes and behaviors of users of mobile devices and computers ("Marketing Information"). This may include information that does not identify you as well as information that does.
Marketing Information in the Oracle Marketing Cloud and Oracle Data Cloud that does not directly identify an individual is information intended to identify a particular computer or device or a group of computers or devices sharing common behaviors or attributes, as well as information about the use of such computers or mobile devices. This information may include, without limitation:
Marketing Information in the Oracle Marketing Cloud and Oracle Data Cloud that directly identifies a particular individual may include, without limitation:
Oracle recognizes that specific types of Marketing Information that do not directly identify an individual may be considered personal information in different parts of the world or when combined with other information. In such cases, Oracle treats this information as personal information.
The Oracle Marketing Cloud and Oracle Data Cloud services and our customers, data providers and partners use a variety of technologies to collect Marketing Information, including via "cookies", "pixel tags”, HTTP headers (or other communication protocols), and mobile signals and identifiers. Oracle does not use flash cookies or other locally stored objects (LSO) that may be used to circumvent consumer opt-out choices.
Cookies are small text files that contain a string of characters and uniquely identify a browser. They are sent to a computer by website operators or third parties. Most browsers are initially set up to accept cookies. You may, however, be able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. Check your browser's "Help" files to learn more about handling cookies on your browser.
Pixel tags are small strings of code that provide a method for delivering a graphic image on a webpage or other document. Pixel tags allow the operator of the webpage or other document, or a third party who serves the pixel tag, to set, read, and modify cookies on, and to transfer other data to, the browser used to view the webpage or other document. Pixel tags may also be used to obtain information about the computer being used to view that webpage or other document, including the IP address of the computer that the tag is sent to, the time it was sent, the user's operating system and browser type, and other similar information (commonly known as the User Agent String).
HTTP headers are transmitted whenever a webpage is viewed, and contain technical information required for communication between a client (your computer or device) and a server (the webpage you visit). Other electronic communication protocols (such as those used for email) also use headers to transmit information. Our customers may transmit information through HTTP (or other electronic communication protocol) headers to Oracle or otherwise direct Oracle to retrieve such information from your interaction with the customer. This may include information about the client browser, the requested webpage, server and other information the customer knows about you, your computer or device (such as a carrier or device identifier). Note: Oracle does not use persistent identifiers like a carrier or device ID to revive a previously opted-out profile or deleted cookie.
Oracle also allows our Oracle Marketing Cloud and Oracle Data Cloud customers, data providers and partners to send us Marketing Information that they have previously collected, including from both online and offline sources. This may include information from customer-lists, website membership, or other information created from a third-party's own technology (such as proprietary modeling or matching technology of other companies).
The Oracle Marketing Cloud and Oracle Data Cloud services use Marketing Information to create profiles and interest segments and to otherwise enable interest-based advertising. A "profile" is a unique set of information about a specific individual, computer or device, or a set of multiple computers or devices sharing common attributes. An "interest segment" is a group of profiles that share a common behavior or preference. For example, we may create an interest segment consisting of profiles interested in "European Automobiles." We create these interest segments based on the information available to us, our experience in the marketing industry, and the preferences and requests of our customers.
We call a profile's membership in one or more interest segments "Interest Data". We disclose Interest Data and other information as described in the "Disclosure of Marketing Information" section below. Our customers use Interest Data to conduct interest-based advertising.
We may prepare reports based on Marketing Information and provide them to our customers. Our customers may use these reports to determine information about available interest segments (such as the number of users in a segment). These reports may also be used for billing, auditing, and other operational purposes. These reports are prepared using aggregated data on users' activity on the websites where Interest Data is collected and used. The interest-based advertising reports provided to our customers do not include any information that directly identifies an individual.
We may also use Marketing Information for research and development purposes, for our internal operational purposes, and to create aggregate statistics for market research or analytics services. These aggregated statistics do not include any information that directly identifies an individual.
Cookies. associates each cookie used for interest-based advertising that we set on a user's web browser with a unique identifier (what we call the "BlueKai ID"). When our data providers, customers, or partners transmit information about that web browser to us, or otherwise direct Oracle to collect information from the interaction between that web browser and a webpage, we use the BlueKai ID from that cookie to store the information into a profile with the same BlueKai ID. For example, a computer with a pre-existing Oracle interest-based advertising cookie may be used to browse airline prices to Hawaii on a travel website one day, and the next day used to browse for used cars on an automobile listing website. Oracle will record that the profile associated with that unique cookie is interested in both travel to Hawaii and used cars.
Cross-Device/Cross-Context Technology. Oracle may also create profiles using cross-device/cross-context technology. This technology is designed to enable Oracle and its customers to connect a user’s Interest Data across the various devices or contexts where the user is consuming digital information and content. For example, a user might use multiple browsers on a single device, or use various devices (such as desktops, smartphones, and tablets), which can result in a user having multiple profiles across these various contexts and devices. Cross-device/cross-context technology is used to connect these various profiles and the corresponding Interest Data from the different contexts and devices.
Oracle does this through both deterministic and statistical methods. Deterministic signals leverage data that does not change, like hashed login IDs that are created by an end user across different devices or browsers. Statistical methods leverage non-fixed data about the device or browsers that help identify devices or contexts, like partial or full IP address and browser version. Oracle analyzes this data to determine if the devices/contexts are likely to be related to a single user. When a probable connection is found, Oracle creates links between the profile IDs and related Interest Data from the different devices/contexts. Oracle customers can then use this linked Interest Data when serving interest-based advertising and other content across the user’s devices/contexts. Users may opt out of Oracle’s use of cross-device technology as described below in the “Opting Out” section.
Other Identifiers. Oracle customers, data providers, or partners may create or collect other unique identifiers and provide those to Oracle. These include IDs intended for advertising use (such as mobile advertising IDs), hashed email or login IDs (such as from email lists or customer databases), or their own proprietary identifiers (such as the Tapad Device Graph). Oracle may create connections between these and other identifiers.
We disclose Marketing Information to our customers for interest-based advertising. Our customers may use third-party service providers, acting on their behalf, to display advertising or other content that reflects a profile's membership in an interest segment.
We may also share Marketing Information with third-party service providers (e.g., data storage and processing facilities or modeling vendors) in order for those service providers to perform business functions for Oracle or on behalf of Oracle customers. When Oracle shares your information with third party service providers, we require them to use Marketing Information only for the purpose of providing services to us and to implement security controls to maintain the confidentiality of that information.
Oracle may use or disclose Marketing Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residencee, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer Marketing Information to the relevant third party.
Oracle sets Marketing Information collected for interest-based advertising to expire within 180 days from the date it is collected. For example, if you last browsed an applicable travel website for airline tickets to Hawaii on January 1, your membership in Oracle’s “Travel to Hawaii” interest segment would expire from your profile by July 1. On an occasional basis, Oracle may permit some OMC/ODC customers to retain Marketing Information for up to 36 months for limited purposes such as seasonal or cyclical interest-based advertising campaigns or internal analytics and model development; such customers are required to delete this Marketing Information at the end of the agreed time period.
Oracle may also retain other statistical data related to the performance, operation and use of OMC/ODC services for more than 180 days for security and operations management, statistical analyses, service improvement, and research and development.
Oracle maintains a consumer tool called the BlueKai Registry, which allows you to view all third-party Interest Data in the Oracle Audience Data Marketplace that is applicable to the computer that views the registry. Within the BlueKai Registry, you may remove individual interest segments at your sole discretion. Keep in mind that the Interest Data you see within the registry is information from the profile associated with the specific browser, computer or device that you are visiting it with. Unless Oracle has linked browsers, computers or devices into a common profile (as described in the "cross-device/cross-context" section above), you may see different segments when viewing the registry from a different browser, computer or device.
Interest-Based Advertising Opt-Out. Oracle offers multiple ways for you to opt out of third-party collection and use of your Marketing Information for interest-based advertising. Opting out does not mean you will stop seeing advertisements, but that the advertisements you do see will not be influenced by Marketing Information collected using Oracle Marketing Cloud or Oracle Data Cloud services.
If your browser accepts cookies, you can opt out directly from third-party interest based advertising by downloading Oracle’s BlueKai opt-out cookie. This cookie, when deposited on your browser, will prevent Oracle's BlueKai technology from creating Interest Data based on information collected from that browser. You can access and learn more about the BlueKai opt-out cookie here. The BlueKai cookie is configured to opt-out for a minimum of 20 years if left undeleted. Please note that if you would like to opt out of both first and third-party use of your information on the Oracle Marketing Cloud and Oracle Data Cloud for interest-based advertising, Oracle encourages you to use the NAI opt-out tool described below.
You may also opt out using tools provided by the following industry groups. (Oracle's participation in these organizations may appear under the "BlueKai" name.)
Note: The opt-out tools described above are currently cookie-based, and prevent Oracle from using Marketing Information for interest-based advertising on the browser on which they are installed. As a result, the opt out will only function if your browser is set to accept third-party cookies, and may not function where cookies are sometimes automatically disabled or removed (e.g., certain mobile devices and operating systems). If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again.
Also note: The Oracle Marketing Cloud and Oracle Data Cloud may interact with third parties who engage in interest-based advertising in conjunction with certain Oracle Marketing Cloud and Oracle Data Cloud services. For example, an Oracle customer may use Oracle Marketing Cloud services to send promotional emails to you, and include tags in those emails that enable a third party to place a cookie on your web browser. The Oracle customer and the third party may use this cookie to collect data about you and engage in interest-based advertising at a later time. Because in this limited circumstance opting out with Oracle's own opt-out cookie will not currently prevent the third parties from collecting or using Marketing Information for interest-based advertising, Oracle encourages you to use the NAI, DAA, and EDAA opt-out tools described above if you are interested in opting out of this sort of activity.
Cross-Device/Cross-Context. If you opt out of interest-based advertising and Oracle has used cross-device/cross-context technology to link that profile to other devices or contexts, Oracle will break the connections from the opted-out profile to those other devices or contexts. If you wish to opt out of the profiles based on your other devices or contexts, you should exercise one of the opt-out options discussed above using each of the devices/contexts (including each browser that you use).
Mobile Opt-Out. The Oracle Marketing Cloud and Oracle Data Cloud allow customers to use Marketing Information collected from mobile devices for interest-based advertising. While the opt-out methods described above often work for mobile web browsing, they are cookie-based and are therefore less reliable in mobile "app" environments that may not accept cookies. As an alternative, Oracle suggests you download Ghostery's Ad Control app. This app allows users to exercise opt-out control for specific companies, including Oracle, and provides a more reliable opt-out signal when you are in a mobile app.
Do Not Track and Cookie Blocking. Oracle does not uniformly process do-not-track signals from browsers. However, you may prevent Oracle from collecting Interest Data using cookies on a browser by blocking third-party cookies in that browser. If you block third-party cookies from being set on your browser, you may not be able to enjoy some features or functionality of, and you may see the same content and advertisements repeatedly on, some websites.
Oracle may add additional opt-out tools over time as they become available.
Industry Involvement. Oracle is a member of the Network Advertising Initiative (NAI) and works with industry-leading companies to address important privacy and consumer protection issues in online advertising. The NAI has created a compliance program that incorporates attestation reviews, a consumer complaint process, sanctions and annual reporting to help ensure that member companies keep their promises to you and abide by the NAI's Self-Regulatory Code of Conduct. Click here to learn more about the NAI.
Oracle also participates in the Digital Advertising Alliance (DAA) and European Digital Advertising Alliance (EDAA) self-regulatory programs and adheres to the DAA and EDAA Principles for Online Behavioral Advertising. Click here to learn more about the DAA. Click here to learn more about the EDAA.
Sensitive Data. Oracle is aware of the sensitivity of certain types of data. We do not create any interest segments that reflect third-party Marketing Information that we consider sensitive. While the types of Marketing Information considered sensitive may vary among users, we presently treat Marketing Information as sensitive if it includes precise health information (such as a user having a certain medical condition like cancer or diabetes); certain aspects of a user's personal life or financial situation (such as credit, insurance or employment eligibility); or use of, or interest in, gambling, alcoholic beverages, or "adult" products or services. If you would like to view the list of third-party health and wellness Interest Data segments available in the Oracle Audience Data Marketplace, please click here. Our customers who collect their own data (first-party data), including those who choose to share their data with other third parties, may have their own standards of what they consider sensitive; however, Oracle requires all such customers to comply with laws applicable to sensitive information.
Children. We do not intentionally collect Interest Data from, and do not tailor any segments to, children under 13 years of age. We prohibit our data providers, customers and partners from providing Oracle with information from sites directed to children under the age of 13 or from users whose age these companies know to be under the age of 13.
The security of Marketing Information is very important to Oracle. We use physical, technical, and administrative safeguards that are designed to protect Marketing Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
In the event that Oracle determines that Marketing Information identifying you and stored in the Oracle Marketing Cloud or Oracle Data Cloud is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Oracle will, consistent with the reasonable needs of law enforcement and subject to applicable law, notify the applicable data provider, customer or partner who provided Oracle with the information so that it may notify you.
Oracle complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Oracle is also responsible for ensuring that third parties acting as an agent our behalf do the same.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Oracle is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Oracle continues to adhere to the underlying European privacy principles of the U.S.-Swiss Safe Harbor for the processing of Personal Information received from Switzerland. To learn more about the Safe Harbor program, and to view our certification, please visit https://safeharbor.export.gov/swisslist.aspx.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Written inquiries may be addressed to:
Chief Privacy Officer, Oracle Corporation
10 Van de Graaff Drive
Burlington, MA 01803
United States of America
Oracle's corporate headquarters are located at:
500 Oracle Parkway
Redwood Shores, CA
Policy Created: August 25, 2016.