1. Introduction to Throtle
Throtle helps the world’s largest brands use their data to improve customer interactions on any channel and device. We provide onboarding data services to marketers engaged in online marketing (such as through use of Data Cookies¬), through our data management platform as well as other data services.
Throtle is a member of the Association for Interactive Marketing (“AIM”), the IAB, NAI and the Digital Advertising Alliance (“DAA”), and we adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You can choose to opt-out of Throtle’s services, by clicking HERE.
2. The Types of Data That We Obtain and Use
Throtle receives data from a variety of consumer-facing companies and services, and data compilers and suppliers. We also obtain data through public sources, such as census data and other public records. Some of the data we use and make available is Personally Identifiable Information (“PII”) or is linked to PI. PI includes, for instance, name, postal address, telephone number or email address. In addition, some of our services involve using and making available “business to business” data, which is obtained from a number of sources, including public directories, filings and publications, surveys and subscriptions.
Throtle does not collect or use individual social security numbers, banking information, or information that we know was collected from persons under eighteen (18) years of age. We accept, but do not store, credit card numbers for payment processing.
We also collect certain information when you visit our website, throtle.io.
3. How We Use Personal Data
We use Personal Information for various purposes. We use it to create “audience data” categories of personal interests that are grouped together based on common interests or preferences (“Data Segments”). These Data Segments may identify a person or, when used online, a unique online identifier, as, for instance, enjoying sports, travel, living in a middle-class neighborhood, or having children. By permitting marketers to incorporate this information into how they send offers to their customers and others, it is more likely that marketers will send relevant and desired, rather than unwanted (and potentially annoying) offers, coupons and ads.
We offer these Data Segments, in different forms, to marketers wishing to reach customers through online (e.g., web/mobile), email, and offline channels.
Using similar technology, we also help marketers to reach their own “CRM” lists – their proprietary “first party” lists of their own actual and prospective customers, along with their proprietary Data Segments. We help marketers reach audiences representing these lists through onboarding their offline data online for digital advertising purposes such as display advertising (for instance, working with partners that de-identify this data), and email marketing.
4. The Services We Provide to Marketers and Advertisers
More specifically, we use Personal Information and Data Segments to provide the following services:
a. Traditional Data Services. We use and make available to marketers PII and Data Segments, and work with marketers’ in-house data in order to help marketers target their digital advertising campaigns and to analyze and understand their users;
b. Providing online marketing services (“Online Ad Services”). We operate Throtle to include tools and applications designed for marketers who wish to tailor display media, ads, and content to target prospective audiences, as well as their own current customers. Throtle also helps marketers target display media to their own customers or prospective customers safely and effectively. The platform can also be used to help marketers coordinate their advertising across channels (such as email and online display). We work with other data distribution and online cookie networks to de-identify Data Segments for use with anonymous online cookies (or similar technology), so that marketers can send display media to users across web and mobile platforms in a privacy-sensitive way. Further, when we help marketers target anonymous offers in this way, we do not place personal information into cookies, and only collect anonymous web browsing information (or tie that information to PII), and we require our data partners to similarly respect consumers’ privacy. We do not use, or authorize other cookie platforms to use, “Flash Cookies” or locally stored objects for purposes of ad targeting. The Data Segments used for this may be comprised of Throtle’s own proprietary data (such as when a customer wants to send ads to, e.g., sports fans or travel enthusiasts) or may be our customers’ own proprietary data (such as when a customer wants to send special offers to its own customers).
In addition, we may help these customers to measure the effectiveness of display media campaigns – for instance, to determine which types of ads are most likely to be seen or opened by which types of customers, or which types of ads are most likely to lead to purchases. When we do this, we respect privacy as set forth above.
c. Other Data Services. We sometimes use PII to provide other data services, such as verification and other analytics and database tools.
d. Providing or Assisting in Cross-Channel Marketing. We may use PII and Data Segments to help marketers and other data platforms in “cross-channel” marketing – analyzing, locating and creating potential marketing “audiences” through multiple channels, e.g., web and mobile.
e. Improving of Our Own Products. We may use certain PII and Data Segments to improve, analyze and develop our own products.
5. How we Respect Consumer Privacy
Consumer privacy is of paramount concern to us. We respect user privacy in the following ways, which we believe meet the highest of industry standards. In addition to other privacy and security protections discussed in this Policy, we adhere to the following:
a. As to our online marketing services, we don’t place personal information into cookies, and when working with data partners we irreversibly “hash” into non-human readable, de-identified form to any personal information they receive from us, before using or sharing it for ad targeting purposes. In recognition of the importance of fully separating online data (e.g., browsing data) from personal information, we employ other, sophisticated technical means to fully segregate databases containing PII from online data, e.g., campaigns that track user conversions.
b. As to all data segments we offer, we do not work with financial or insurance account information, social security numbers, or information about individuals’ health or ailments;
c. We provide multiple opt-out channels, as described below in Section 6.
d. We contractually require our online partners to provide appropriate notice and opt out choice to their own customers and users.
6. Your Opt-Out Rights
You may opt out of Throtle’s cookie-based Online Ad Services. If you decide to opt out, we will set an opt-out cookie (or similar technology) on your browser or device, to indicate to us that you have opted out. Please note that if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device to ensure that we withhold our Online Ad Services on all of them. For the same reason, if you procure a new device, change browsers or delete the Throtle (or clear all cookies), you will need to perform this opt-out task again.
If you wish to opt out of other third party ad platforms and ad networks (including ones we work with and may have transferred data to in the past), we recommend visiting the opt-out pages offered by the Network Advertising Initiative [NAI] and the DAA’s AboutAds program. Opting out in this way will not prevent you from seeing ads: it will prevent targeted ads customized to what ad exchanges (and as to our opt-out, we) believe are most likely to be relevant and of interest to you.
7. How We Work With and Share Data With Third Parties
Throtle may share data, including Personal Information, as follows:
Agents and Service Providers: We may share data, including PII and Data Segments, with agents and service providers who work on our behalf, or to help us provide services requested by our customers. We may do so, for instance, for analytical purposes, to measure campaigns, or inform future campaigns. We may do so to facilitate the sending of display media, or other requested services. These agents and service providers do not have an independent right to use or share any Personal Information.
Partners: We may share data, including PII and Data Segments, with business and data partners to help provide more tailored advertising and for analytical purposes. However, Throtle does not share PII with ad networks, i.e., platforms that serve advertising on other third party websites.
Affiliates, Parents and Subsidiaries: Throtle we may share some or all of the data in our possession with affiliated or subsidiary companies.
As Required by Law or to Protect Any Party: Throtle may disclose data if we believe that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Throtle or any other party.
8. Cookies That We Use
Throtle uses industry-standard technologies, including cookies and similarly functional technologies. Throtle cookies do not contain personal information, and expire within 24 months (and often over a shorter time span than that).
We may work with third parties to enhance our Services (e.g. for purposes of retargeting and tailoring ads, or placing browser cookies). These partners may set and access their own cookies, pixel tags and similar technologies on your Device, which may have cookies with varying expiration period. Those partners may, likewise, collect various types of anonymous or de-identified information about your browser, device, or browsing activities through use of these cookies.
9. Sensitive Information, and Information Pertaining to Children and Health Conditions
Throtle does not manage or store Data Segments containing or identifying personal information, financial records, health conditions or medical ailments, or data that we know (or learn) is obtained from children under eighteen (18) years of age.
The above only applies to the data that Throtle itself directly provides – our customers, data partners, ad networks or other platforms with whom we work may use or make available their own, distinct sets of data.
10. Security and Data Integrity
Throtle takes significant steps to help ensure that the data we possess is housed and transmitted securely. We use multiple layers of physical and electronic security, including firewall protections, encryption of data during transfer, and strict access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ multiple, substantial efforts to ensure that this does not occur.
11. Questions or Concerns
If you have questions or concerns about Throtle’s privacy efforts or products, please contact us at:
ATTN: Privacy Officer
141 West Front Street, Suite 410
Red Bank, NJ 07701
Or, you may email us at email@example.com.
Our Policy on cookies and other tracking technologies:
A ‘cookie’ is actually a file that our web server or the web server of one of our third-party partners may send to your computer when you access our website. This file is then stored on your computer.
- After you have visited certain pages on our website, cookies enable the site to ‘remember’ that information. Cookies and other passive information collection technologies enable us to deliver content that is tailored to interests, browsing history and preferences based on your activity on the site.
- Cookies and other passive information collection technologies enable us to compile aggregate statistics concerning use of the site, analyze trends, and otherwise administer and improve the site.