1. About Invisibly’s Services
Invisibly provides advertising services for our brand partners (“Advertisers”), as well as content monetization services for our publishing partners (“Publishers”). Users of our Publishers’ websites benefit from seeing fewer, more relevant ads, and in exchange, receive a credit from the Invisibly platform which can be used to access quality content on thousands of sites.
2. What data we collect
We collect the following categories of information for the purposes explained below.
- Activity on Publishers’ Digital Properties: This is data about your browsing activity on the Publishers’ websites. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, what type of articles you liked reading, and how many articles you read.
- Device and browser information: This is technical information about the device or browser you use to access the Publisher’s website. For example, your device’s IP address, cookie string data, operating system, and (in the case of mobile devices) your device type and mobile device’s unique identifier.
- Ad data: This is data about the online ads we have served you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.
- Data you may provide us: This is data that we lawfully receive from you during your use of the Invisibly platform, i.e. while you’re viewing ads and consuming content on the publishers’ websites. For example, we may serve you an experience with a prompt to take a survey, answer a question or to take some other action, which in the aggregate lets us learn about your preferences. This data lets us provide you with content you value the most in a personalized experience.
3. How we use the data we collect
For Advertisers, we use this data to identify and serve ads to you that are more relevant and enjoyable for you. For Publishers, we use this data to identify what content you enjoy most, and to match the value of the Advertising you’re credited for viewing against the value of the content you’re consuming, in other words – to sustainably monetize content. We also use this data to operate, improve and enhance our Advertiser services including enhancing the data points we or our Advertisers have about a particular user, browser, or device to serve the most relevant ads to you and, in turn, improve performance of an Advertiser’s ad campaigns. Specifically, we use this data for:
- Targeting: Selecting ads that are more likely to be relevant to you based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads.
- Frequency capping: Making sure that you don’t see the same ad too many times.
- Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.
- Cross-device matching: Identifying all devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices. It also helps us match devices so we can honor your opt-out choices across all devices we know are connected to the opted-out cookie.
- Attribution: Monitoring when, where, and at what price we served certain ads on behalf of an Advertiser so that we can measure our influence on the marketing result of the Advertiser’s campaigns and overall marketing strategy.
- Reporting: Providing Advertisers insights into how their ads are performing and gain insights into their customers. Reporting may include ad metrics such as impressions, clicks, and conversions (however the Advertiser may define a “conversion,” for example, a sale or a white paper download).
4. Our legal basis for processing personal data (European Territory Visitors only)
We provide the representations and information in this Section 4 in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). They are specific to persons located in EEA countries or Switzerland, so please don’t rely on the below, if you’re not in one of those countries.
However, we will normally collect personal data from you where the processing is in our legitimate business interests to, for example, administer our platforms and services and fulfil our contractual obligations as a service provider.
In some cases we may collect and process personal data based on consent. To the extent our publishing and advertising partners need to collect and share, or allow us to facilitate collection and sharing of personal data to enable our services, it is the responsibility of these parties to provide necessary privacy notices and obtain required consent(s).
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, then please contact us using the contact details provided under the “Contact us” heading below.
5. Data Sharing
We may disclose anonymized information about you, and or information about the Invisibly Network Audience in the aggregate:
- With a Publisher whose Digital Properties you have visited: We may share information about how you have interacted with that Publisher’s content and site.
- With an Advertiser with whose advertisements you have engaged: We may share information about how you interacted with ads over time across the Digital Properties.
- With our service providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
- With service providers to our Advertisers: Our Advertisers may contract with companies who handle data (such as managing Advertisers’ customer lists) for them.
- In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of Invisibly, our Advertisers, our Publishers, or any other third party.
- To Comply with legal process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
- To Investigate Wrongdoing and Protect Ourselves or Third Parties: To enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
6. Cookies and related technologies
Tracking cookies enable us to identify your device when you move between different Digital Properties, so that we can serve targeted advertising to you.
We may also drop cookies from our Advertising Partners for the purposes described above. The Advertising Partner cookies dropped will vary depending on who the Advertisers are.
Additionally, we use non-tracking cookies (not unique) to store user decisions in terms of your ad and opt-out choices
- We may drop a cookie with value opt-out if you opt-out as described below and an Invisibly consent cookie to track your consent choices.
- We may drop a consent cookie that stores the choices you have made regarding data processing and advertising by Invisibly.
7. Your choices and opting-out
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:
You can opt out of receiving personalized ads served by us or on our behalf by clicking on the icon that typically appears in the corner of the ads we serve and following the instructions provided. Please note that this “opt out” function is browser-specific and relies on an “opt out cookie”: thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again.
In some cases we may link multiple browsers or devices to you. If you opt out of on a browser or device and we have more linked to you, we will extend your opt out decision to the other linked browsers and devices. Since we only link users across browsers on devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
Please note that when using the ad industry opt-out tools described above:
- If you opt-out your browser may still send us data, for example your IP address. However, we isolate this data and do not use it other than for accounting and, in some cases, for fraud prevention. If you have opted-out on that browser, we do not use this data to personalize ads or to track you.
- If you use multiple browsers or devices we will additionally opt out those we have linked to you. Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt out on each browser or device.
- To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:
- iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
- For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
Some internet browsers allow users to send a “Do Not Track” signal to websites they visit. We do not respond to this signal at the present time.
In addition, if you are located in a European Territory you will also have additional data protection rights. These are described under the heading “Additional data protection rights for European Territory residents” below.
8. Data retention
Personal data collected is held no longer than necessary for our business purposes but is anonymized. For example, we retain anonymized impression and click data to ensure we can meet auditing requirements related to services provided or to meet legal requirements.
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
10. International transfers
We may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. In general, these countries will be the countries in which we, our Publisher, our Advertisers, or our or their service providers operate.
If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.
12. Contact us about questions or concerns