Privacy and other policies

Facilitate Digital recognise the importance of adhering to regulatory frameworks proposed by leading industry groups and associations. Facilitate Digital privacy compliance is outlined below, incorporating client, consumer, SPAM, Cookie Opt-out and IP-Address Data Handling policies.

Client Privacy

Facilitate Digital distinguishes between proprietary and non-proprietary client information. Proprietary information refers to information which was sourced from a client’s proprietary database (such as a customer database) or to any other information that was obtained by virtue of the client’s advertising spend and is personal information about the consumer.

Examples of this information are identifying details of customers obtained by virtue of an advertising campaign.

Facilitate Digital will only provide proprietary information to another client if the original client provides written authorisation for us to do so. On request from a client, Facilitate Digital will return or destroy all Proprietary Information belonging to that client.

Non-proprietary Information

Non-proprietary information is information that is:

1. Not sourced from a client’s proprietary database (such as a customer database); or
2. Not obtained by virtue of the client’s advertising spend; or
3. Was obtained by virtue of the client’s advertising spend but is Non-personal Information (see Facilitate Digital’s Consumer Privacy Policy for the distinction between non-personal and personal information).

An example of the distinction between proprietary and non-proprietary Information obtained by virtue of a client’s advertising spend would be where consumers fill out the results of a form as part of a campaign.

Information relating to the consumer’s name, address and other personal information (see Facilitate’s Consumer Privacy Policy) obtained through consumers completing a form at the client’s web site would be regarded as proprietary information.

Information obtained from forms or any other method that relate to non-personal information (see Facilitate Digital’s Consumer Privacy Policy) is treated as being non-proprietary information.

Non-proprietary information is kept and used by Facilitate Digital to provide targeted advertising and to allow clients to better meet the needs of customers.

Information collected through Surveys

Facilitate Digital uses the information collected through our surveys to further enhance our product and service offerings. All information collected via surveys is entirely voluntary and individual survey responses and personal information will not be identified to any third party without your express prior consent.

Facilitate Digital understands that you may be concerned about the confidentiality and security of the personal information we collect from you through such tools as surveys. To address this, we have security systems in place to ensure information about you is kept as secure and confidential as possible. Access to survey data is strictly controlled to authorised personnel for approved purposes.

Consumer Privacy

Facilitate Digital distinguishes between personal and non-personal information. Personal information is information that identifies the individual user such as names, addresses, telephone numbers, etc. non-personal information is information that does not identify the individual.

Personal Information is only obtained by Facilitate Digital on a voluntary basis. In order for us to use this personal information, a user must actively submit it. If you would like your personal information removed from our databases, or updated, please send an email to disclosure@facilitatedigital.com.

Non-Personal Information

Non-personal information is obtained by Facilitate Digital via our Web Servers. Facilitate Digital may use this information for our Ad Serving and Targeting businesses. This information may not identify your individual details and is likely to be routinely visible to numerous Internet companies besides Facilitate Digital.

Non-personal information is used by Facilitate Digital to enable our clients to better meet your needs, through the supply of appropriate advertising and tailored content.

Use of Cookies

A cookie is a piece of data stored on a user’s hard drive that can contain information such as banners seen or sites visited. Facilitate Digital may use cookies for a number of purposes.

These include:

1. Aggregated and cumulative information such as reach and frequency of a given banner or campaign
2. Ensuring that the appropriate click through is used for a given banner
3. At present Facilitate Digital does not use cookies to measure and track individual’s Internet surfing habits or any other profiling information. Nor are they used to obtain personally identifiable information

Cookie Opt-out

If you do not wish to receive cookies in future from Facilitate Digital, you may choose to opt-out by clicking the link at the end of the paragraph. This will send a request to a page on our servers where a single opt-out cookie will be placed on your browser which will be used to identify your request. After this has occurred whenever a request is sent to our system, either when viewing or clicking on an ad, we will look for the opt-out cookie and, if present, will not send a request to set a cookie for the called domain to your browser. Please note that this will not stop you from seeing advertising, may adversely affect ad delivery and will only continue to work as long as the cookie is present on your current browser. The use of cookie blockers, internet filters and any program that may alter your internet viewing experience may prevent this from working. Click here to opt out.

SPAM

Spam is the term used on the Internet to describe unsolicited e-mail messages. These messages are also commonly referred to as junk, bulk or unsolicited commercial e-mail (UCE).

Express mail prohibits the use of our system for spamming. We may, at our discretion, refuse to send any broadcast job which meets commonly accepted definitions of spam. We also reserve the right to terminate service or take other appropriate actions against customers who violate our policies.

We require Express mail customers to only use lists of e-mail addresses containing recipients who have given explicit consent to receive e-mail from our customers. Also, customers must not use lists that have been obtained from public Internet forums or any other source, either by the Express mail customer or a third party.

In addition to unsolicited messages, Express mail also prohibits the delivery of illegal material.

All e-mail originating at Express mail is clearly identified as such, and no attempt is made to obscure or alter header information. Express mail does not allow outside hosts to relay mail. Express mail will strictly ensure the enforcement of this policy.

Express Email offers an automated blocking feature. If a Express Email customer sends you an unsolicited message, you need only reply to the offending message with the word “remove” (no quotes) at the beginning of the Subject: line.

Express Email will block the offending customer from sending to your address via our service, and will send you one additional e-mail confirming the block. Instructions on how to do this are attached in plain language to every message transmitted via Express Email.

Additionally, you can bring to the attention of spam@facilitatedigital.com any Express Email customer you believe has sent you e-mail that is unsolicited. Our Express Email abuse staff will investigate, take appropriate action and inform you of such.

Our system blocks the address that the offending message was originally sent to insuring that the block will be effective, even in the case of aliasing or forwarding.

At Express Email, we provide our customers with reports of recipients who have asked to be removed from that customer’s lists. Although Express Email does not maintain lists, we provide these reports to our customers so that they can clean their lists. Express Email blocks delivery to such addresses in any case.

If you wish to be blocked from ALL Express Email customers, we can do that too. To be blocked from ALL future mail from any Express Email customer, please send e-mail to clientservice@facilitatedigital.com and ask for a “system block” of your address. Please be sure to include the address you wish blocked, to help possible confusion with mail aliases or forwarding systems.

IP-Address Data Handling

Facilitate Digital confirms that no personally identifiable information of users is stored in the Facilitate Digitals databases. The IP-Address of a user is converted into an encoded number and only used if agencies select the geographic reports.

If a campaign does not use Geographic reporting then Facilitate Digital does not use the IP-Address at all.

If you have any concerns or comments about any of the information supplied above, please email disclosure@facilitatedigital.com