Introduction to Throtle
Throtle helps brands to use their own customer data, along with other licensed data, to improve customer interactions on multiple channels and devices. For instance, we provide data “onboarding” 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 and platforms.
We are a member of the Network Advertising Initiative (NAI) and adhere to the NAI’s Code of Conduct. You can click HERE to reach the Network Advertising Initiative site, a central location for information about Interest-Based Advertising and the choices available to you, and to opt out of receiving third-party Interest-Based Advertising via cookies from us and NAI member companies. Throtle is also a member of the IAB. You can choose to opt-out of Throtle’s offline services HERE. and our online services HERE. We describe other opt-out methods and channels in Section 6, below.
The Types of Data That We Obtain and Use
Personal Information. We sometimes use or receive information that identifies people by name, address, or email, along with information about those people’s likely preferences, interests, or demographics. An example of this would be if we know that John Smith owns a home in a particular suburb, and is 53 years old. We obtain this data ourselves and through data licensors, and its source may be, for instance, census bureau data, public records, or data aggregators that collect or receive information from consumers, websites, or business transactions.
Passively Collected Information and Identifiers. This is information that we or our business partners collect passively through websites or mobile devices (or other devices), including cookie IDs, Apple mobile IDFA identifiers and Android mobile Advertising IDs, or unique identifiers tied to those identifiers. These identifiers generally identify or are linked to particular browsers and devices. We refer to all of these identifiers as “UIDs,” and they often are tied to particular browsers and mobile devices (or other devices, such as set-top boxes). (These UIDs in turn may be “synced” or linked across multiple online content providers, ad networks, and other service providers.) We describe these identifiers in more specific detail in Section 5, titled Cookies, Pixels, and SDKs That We (or Our Business Partners) Use.”
Web and Mobile Log Data. Passively collected information we receive may also include a range of data about web and mobile logs and usage, such as the type of browser or device (or operating system) being used, an IP address, a time-stamp, other information about a user’s device or browser, and information about whether and how a user viewed an ad or interacted with content or visited a particular website (sometimes referred to as “clickstream data”). It may also include geolocation information related to a particular mobile device, e.g., the latitude/longitude coordinates that a particular device was located at a given time, or over a period of time.
How We Use the Service Data
Generally, we use the Service Data we receive and collect in order to provide marketing, advertising, and analytics services to our marketers and brands, including through various business partners. We describe our services generally below, and additional descriptions may be contained on this website.
Data “Onboarding” Services. We use Service Data to help marketers to reach their own “CRM” lists – their proprietary “first party” lists of their current and prospective customers – or other audiences, through third party display media platforms. We often help marketers reach audiences representing these CRM lists (or other lists) by “onboarding” their offline data online for digital advertising purposes such as display advertising. When we do this, we often work with partners that de-identify this data, and connect it in de-identified fashion to display media, or other marketing channels.
Enabling Cross-Channel Marketing. We may use the Service Data to help marketers and other data platforms in “cross-channel” or “cross-device” marketing – analyzing, locating and creating potential marketing “audiences” through multiple channels, e.g., web and mobile. For instance, we may link Service Data and UIDs to the same user (based on inferences we have made), so that a marketer can “find” their same audiences through web-based, mobile, or other advertising channels.
Creating Data Segments. We also use our Service Data to create online, mobile or other consumer audiences, represented by UIDs or personal information 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, we believe it is more likely that marketers will send relevant and desired 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, often working with the types of partners we describe above.
Campaign Measurement and Market Research. We sometimes use the Service Data to help marketers measure the effectiveness of display or other media campaigns – for instance, to determine which types of ads are most likely to be seen, opened, or to lead to purchases, or to perform other market research.
Other Campaign and Data Services. We sometimes use our Service Data to provide other data and marketing services, such as verification, data or audience analytics, data modeling, or other services that may be described on this website.
Improving Our Products. We may use our Service Data to improve, analyze and develop our own products and to analyze their effectiveness, or to work with a business partner or client to perform similar services.
How We Work With and Share Data With Third Parties
Throtle may share any data it holds, including Service Data and Website Data, as follows:
Agents and Service Providers: We may share Service Data and Website Data with agents and service providers who work on our behalf, or to help us provide services requested by our customers, and with our customers themselves. 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.
Partners: We may share Service Data (including Data Segments), with business and data partners to help provide more tailored advertising and for analytical purposes.
Affiliates, Parents, Subsidiaries and Successors: Throtle we may share some or all of the data in our possession with affiliated or subsidiary companies. We may also share any data with a successor in interest who purchases all or most of our assets, or in the course of any transaction leading to such an acquisition, i.e., during due diligence.
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.
Cookies, Pixels, and SDKs That We (or Our Business Partners) Use
This section provides more information about cookies and similar technologies that we, our clients and their service providers, and our business partners may use, and how they work.
Pixels or Web Beacons. Pixels, sometimes called web “beacons,” may also communicate information from your internet browser to a web server. Pixels can be embedded in web pages, emails and even videos, and can allow a web server to collect or read information from your browser, determine whether you have viewed particular web content or emails, or determine your IP address or the URL you are viewing content. We often work with business partners (who are themselves third party providers) to provide our services, and these partners often set and access their own cookies, pixel tags, and use other technologies to interact with your device, which may have cookies with varying expiration periods. These partners also may collect various types of information, often in anonymous or de-identified form, about your browser, device, or browsing activities through these cookies.
Mobile Identifiers and SDKs: We may also work with partners who use mobile “SDKs” (software development kits) to collect information about how users interact with mobile apps, platforms, and systems, including third party ad networks. The SDK is computer code that pap developers can include in their apps to enable ads to be shown, data to be collected, or to optimize or improve their apps in other ways. These SDKs may collect (and provide to us) information such as mobile identifiers (e.g., Apple IDFAs and Android Advertising IDs), precise location data (such as lat/long coordinates), and information about what apps a user engages with, mobile devices information, and how users interact with ads. To avoid having ads tailored to you in this way on your mobile device, please following the instructions in the below Section 6, titled “Your Opt-Out Rights.”
GDPR Compliance Statement
The General Data Protection Regulation (GDPR) is effective as of May 25, 2018 across all European Union (EU) member states. In short, if you process data about individuals in the context of selling goods or services to European citizens in any EU country, then you will need to comply with GDPR.
At the bare minimum, the GDPR was drafted with the intended purposes of protecting all non-anonymized personal data (or personally identifiable information: PII). And any company (or organization) that stores or processes personal information about “natural persons” (individual human beings) who are “data subjects” under the Regulation — defined as European citizens who reside in an EU state — must comply.
While GDPR is not a U.S. government policy, U.S. companies must take steps to either block EU users or implement processes that ensure compliance. Throtle welcomes the arrival of GDPR as it builds on the trust that employees, customers, consumers and other stakeholders should have in our industry’s ability to deliver transparency and ensure privacy compliance. This includes Throtle’s ability to apply a high level of data protection and security in relation to personal data that our employees, customers and third parties entrust to us.
Throtle considers it not just its duty to comply with national and international data protection regulations, but also to do this by applying the transparency, predictability and consistency that our stakeholders expect from us.
Throtle’s Policy Regarding EU Data, Protection & Security
Any personal data that is based in any EU member country, including the UK, will be destroyed immediately. It is our policy to not accept any personal data where an individual resides in any EU member country. Throtle perform scans on all data that we ingest, from sources, partners and clients, to identify non-US postal and foreign email domains. In addition, we work with our partners and sources to inform us is they are ingesting any data from outside the US. Throtle regularly cleanses its Identity graph to remove any linkages that are found to originate outside the United States.
Although we have already have a substantial and consistent level of data protection and security in our data centers. At such time that Throtle begins to do business with firms using data based in the EU we intend to be fully GDPR compliant. This includes keeping internal records of all our data processing activities and having a process to accommodate the rights of our data sources as well as consumers.
Your Opt-Out Rights
Some of our services involve the use of inferred user interests and preferences collected or employed across multiple websites, devices or channels. These services are often referred to as a type of “Interest-Based Advertising” or “IBA,” and we provide a way for consumers to “opt out” of these IBA services. If you decide to opt out of our IBA services, we will set an opt-out cookie (or similar technology) on your browser or device, to indicate to us that you have opted out. You may opt out by clicking here.
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 IBA services on all of them. For the same reason, if you procure a new device, change browsers or delete your Throtle opt-out cookie (or clear all cookies), you will need to perform this opt-out task again.
If you want to opt out of other third party ad platforms and services (including some that we work with, and may have transferred data to previously), we recommend visiting the opt-out pages offered by the Network Advertising Initiative (the NAI) and the Digital Advertising Alliance (the DAA). Opting out in this way will not prevent you from seeing ads: it will however, generally prevent ads that are “targeted” to inferences made about your preferences based on your activity across websites and over time.
If you want to opt out of “cross-app” advertising – essentially, the mobile equivalent of IBA, e.g., the use of your mobile app activities over time and across apps to help inform your ad preferences – you generally can opt out through your device “settings.” Common device settings are as follows:
For Apple Devices: If you have an Apple device, you can opt out of most app-based tracking for IBA by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to “On.” You can do this by clicking on Settings > General > About > Advertising and toggling Limit Ad Tracking to “On.”
For Android Devices. If you have an Android device, you can opt out of most app-based tracking for IBA by opening the Google Settings app on your device, selects Ads, and then selection the option to opt out of interest-based ads.
Please note that these platforms control how these settings work, so they above may change, at their discretion. Likewise, if your device uses other platforms not described above, you should check the settings for those devices.
Information Collected On This Website
This website is mainly directed to businesses that may wish to use our services, but we of course welcome consumers and others who want to know more about the data we collect and services we offer. When you visit this website, or contact us by email, we may collect the following Website Data:
Personal Information: If you provide us with information through our website – for instance, if you give us your email to sign up for an event or webinar, or to request materials – we may request and receive certain information, like your name, email address, company name and address, or other information. We may use this information for any business purpose, including to administer your account, provide you services, market to and communicate with you, and analyze how people use our services and websites. We will also provide the information to any successor entity, or during due diligence.
Passively Collected Information. We collect other information (or allow third parties to do so) when you visit our website, similar to the information that we describe in Section 2 describing our Service Data. This includes cookies, web log data, IP addresses, and UIDs, including information about how you engage with our website (or if you are on another website, with our ads), as well as information about your browser or device. We may use this information to target or “retarget” ads to you on other websites or mobile applications. For instance, if you spend time viewing a description of an event we are holding on our website, we might “retarget” you with an invitation to that event. You can opt-out of such targeting through the same channels we describe in Section 6, immediately above.
Sensitive Information, and Information Pertaining to Health Conditions.
Throtle does not generally offer for public use Data Segments we have created containing or identifying sensitive health conditions or medical ailments, or regarding a person’s sexual orientation. This only applies to the data that Throtle itself directly provides, however — our customers, data partners, ad networks or other platforms with whom we work may use or make available their own, distinct sets of data.
Security and Data Integrity
Throtle takes steps to help ensure that the data we possess is housed and transmitted securely. We use multiple types and 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 make substantial efforts to ensure that this does not occur.
Our Service Data and Website Data are generally stored on servers in the United States. If you are accessing our website, or if your information is used in our services, and you are located in another country (such as a nation within the European Union), you should know that the laws governing various types of data in the United States may be different or less protective than those of your own country, and you may wish to consider that factor in deciding whether or not to “opt out” or our or other similar data services.
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.
Last updated on June 20, 2018.