PRIVACY POLICY

Our commitment to privacy: Eyereturn Marketing Inc. (“Eyereturn”), understands that protecting the privacy and confidentiality of your information is important to you. This Privacy Code governs the collection, use and disclosure of your information in any form, whether written or electronic, by Eyereturn. This Privacy Code explains what information may be collected from you and how it is used. It also explains how you can ask questions, make suggestions, and express concerns about our privacy practices.

This Privacy Code applies only to the information collected by Eyereturn. The collection, use and disclosure of your personal information is governed by applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (the “Act”), and any applicable provincial legislation. Eyereturn does not collect any personally identifying information in connection with the delivery of our services for our clients, including the presentation of advertisements or customized content, nor from the websites and apps in which those advertisements appear.

If you have any concerns or questions, we encourage you to contact us and we will address your concerns to the best of our ability. Please read this Privacy Code carefully, and check back periodically as we may update it from time to time.

WHAT INFORMATION DO WE COLLECT, AND WHY?
Eyereturn serves advertisements on behalf of hundreds of third party advertisers across numerous publisher websites and mobile applications.  Eyereturn also assists our clients who operate websites to present customized content that is believed to be more relevant to you.

When you visit a website or mobile application (“app”) where Eyereturn is delivering ads, or the site or app of a customer Eyereturn serves ads on behalf of, or a site or app where Eyereturn is facilitating custom content,  Eyereturn may collect information about your online activities and approximate location in order to show you relevant advertising and content.  Eyereturn is exposed to device latitude and longitude data passed to us via programmatic media buying opportunities, which in some cases may describe a precise location. Eyereturn may store this location information however it is rendered imprecise prior to use for targeted advertising. We may collect information such as which ads have been shown you, on which pages, and how you responded to them. We may collect information about your interactions with customer sites—for example, by placing tags on an advertiser’s web site to measure purchase events for items they had worked with Eyereturn to advertise or tags on a web publisher’s site to measure your interest in particular types of content.  Due to the underlying mechanics of the Internet, Eyereturn is exposed to information about your device, such as IP address, unique device identifiers, browser type and language settings, and operating system information.

TECHNOLOGY UTILIZED
None of the following technologies are used to identify individual people. Rather, they are used to uniquely identify a device or a browser within a certain level of confidence that enables Eyereturn to serve more relevant ads and / or custom content.

Site Tags
Site tags, also commonly known as pixels or beacons, are used to help web publishers understand how visitors interact with their websites and their advertising campaigns. Site tags are transparent, and maybe HTML image tags, iframe tags, or JavaScript tags that are installed on a site. The use of these tags allows a website to measure the actions of the device loading the page that contains the tag.

Cookies
If you load a publisher’s website on which Eyereturn is serving an ad or delivering custom content, we may assign an HTTP cookie. A cookie is a small file assigned to your Web browser that can collect and store information. We use cookies to better understand how you use websites, to make sure ads are served correctly, and for analytics and reporting purposes. For example, a cookie may be utilized to limit exposure to specific ads. The information stored in Eyereturn cookies is not linked to any personally identifiable information.

We set our browser cookies to expire after two years. The cookie expiration date will be updated each time a browser requests resources from our server. Device level segment data inside the cookie may be retained for the lifetime of the cookie, in the cookie, however data stored inside the cookie is aged, and often will be deleted in a period of hours or days. We collect Non-PII segmentation data (data which cannot reasonably be used to identify an individual) in server log files. These logs are processed daily for aggregated ad delivery and reporting summaries. The data in the log files cannot be tied to specific browsers. The summarized reports are kept indefinitely.

If you are concerned about cookies, it is possible to turn them off in your web browser preferences. However, please be aware that by disabling cookies, your web surfing experience will be degraded.

We may use IP (internet protocol) addresses to undertake aggregate browser statistics, determine the approximate location of browsers, diagnose problems with our servers, and optimize and administer our services.

We may track and analyze Non-PII usage and browsing patterns of visitors to customer’s websites to provide our advertisers with more targeted advertising opportunities and to help users see advertising that is most likely to interest them. We may also use this information to assist our customers in presenting customized and more relevant content.

Statistical IDs
Statistical IDs are created via an algorithm using non-personally identifiable and pseudonymous information about a computer or device. The information used may include the operating system, user-agent string, Web browser, approximate location, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device. These IDs are not used to target advertisements, and are only used for campaign analytics and reporting purposes.  It should be noted that browser controls do not affect statistical IDs. Statistical IDs rapidly become obsolete, and generally lose their linkage to a distinct device in less than one month.

Third Party Data
We may receive information about consumers from third parties to enable targeted advertising on the website(s) and application(s) that we support. The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Eyereturn Marketing.

SENSITIVE INFORMATION

Eyereturn does not collect or aggregate information based on sensitive health conditions to tailor ads on behalf of our advertiser clients. In order to provide transparency on which data segments that are collected and used by Eyereturn, the health related segments we create are listed here.

WHO DOES EYERETURN DISCLOSE INFORMATION TO, AND WHY?

Eyereturn may disclose your information under the following circumstances:

Your information may be processed and stored outside of the province in which you reside and/or outside of Canada by us, an affiliate or a third party service provider for the purposes set out in this Privacy Code and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your information.

Eyereturn may disclose your information to third parties if you have violated our terms of service, or if we need to comply with applicable laws and lawful governmental requests, other legal and regulatory authorities and for other legal reasons.

For those sites where Eyereturn assists the publishers with customized content, Eyereturn may communicate with the publisher regarding inferred preferences so that the publisher can tailor the content it presents. These inferred preferences are limited to categories of interest and no personally identifiable information is communicated.

CONSENT AND OPT-OUT POLICY

In general, Eyereturn seeks consent to use your information in accordance with our opt-out policy. Except as set out in this section, eyeReturn obtains your express opt-in consent to use or disclose sensitive information.

If you do not wish to have Eyereturn use your information for tailoring advertisements and the presentation of customized content, you may opt-out at any time by doing any of the following:

Web browsers
Please check your opt-out status below. If you have not opted-out, you will see an “Opt-out” button. Please note that if you delete or block party cookies, change Web browsers, or use a different computer, you will need to undertake the opt-out again.

Please note that you will still see ads if you opt out. The ads will just not be as relevant to you. An opt-out will be effective with respect to tailored advertising and customized content. You cannot opt out of one and not the other.

Mobile Device Applications
Most modern mobile operating systems (iOS 6, Android 2.3, and Windows 10 and above) provide mobile advertising identifiers for mobile devices. These identifiers have different names depending on the brand. For example, they are called Google Advertising ID (GAID) on Android devices and Identifiers for Advertisers (IDFA) on iOS. These identifiers are commonly used to help enable digital advertising across mobile applications. The operating systems that provide these mobile advertising identifiers tend to include built-in settings to express privacy preferences for online advertising across applications.

For instructions on how to opt your device out of Cross-App Advertising, follow the directions posted here: http://www.networkadvertising.org/mobile-choices

You may opt-out of interest based advertising and online behavioural advertising where applicable by clicking the adchoices icon on ads appearing across our network or by visiting http://youradchoices.ca/choices/ and https://networkadvertising.org/understanding-online-advertising/what-are-my-options.

General Notes
Eyereturn is a member of and conforms to the standards of the following self-regulatory organizations:

The Digital Advertising Alliance of Canada (DAAC). To learn more or to opt out of targeted advertising from other DAAC members, please visit youradchoices.ca/choices.

The Digital Advertising Alliance (DAA). To learn more or to opt out of targeted advertising from other DAA members, please visit www.aboutads.info/choices.

Generally, when you provide us with your information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Code, if applicable, or otherwise at the time of collection. We reserve the right to use and disclose your information without your consent where required or permitted by law, for example, if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law, in order to protect or defend our legal interests, or to comply with applicable laws and lawful governmental requests.

SAFEGUARDS

Eyereturn has technical, contractual, administrative and physical security measures to protect your information in a manner that is reasonable and appropriate to the nature of the information you provide to Eyereturn.

Other than as permitted or required by law, if we wish to collect, use or disclose your information for purposes that are not contemplated in this Privacy Code, we will identify those purposes at the time of collection. You will be given a reasonable opportunity to opt-out of any such additional purposes.

HOW TO ADDRESS CONCERNS REGARDING YOUR PRIVACY

Eyereturn encourages you to contact us with any questions or concerns you have about your privacy or this Privacy Code. If you have a question concerning the Eyereturn Marketing Inc. Privacy Code please contact us at: privacy@eyereturn.com.

If after contacting Eyereturn your concerns or questions have not been resolved to your satisfaction, you can contact Eyereturn’s Chief Privacy Officer in writing as follows:

Chief Privacy Officer
Eyereturn Marketing Inc.
1 Yonge, 4th Floor
Toronto, Ontario
M5E 1E6
Fax: 1 (416) 929 6046

This Privacy Code was last updated in March 2020