This policy was last modified on and has an effective date of September 19, 2019.
If you are a resident in the European Economic Area (EEA) and want to find out more about your data protection rights, please see Data Subject Requests.
Our Platform is intended for use by our clients – and for the most part – we collect and process personal information through the Platform as a data processor on behalf of our clients (the client is the data controller). Please also note that in certain use cases this policy applies to the personal information we collect and process through the Platform as a data controller.
We are not responsible for the privacy or security practices of our clients, which may differ from those set forth in this policy. We require our clients to comply with all applicable laws and regulations and to provide you with notice of the collection of data as outlined in this policy. To understand how clients will use your personal information, please refer to the relevant privacy policies for those clients.
Information We Collect
How We Collect Usage Data
How We Use Your Information
How We Share Your Information
Your Privacy Choices & Opting Out
Additional Notice for EEA Residents
Data Subject Requests
How to Contact Us
Our Platform helps clients collect, manage and distribute their data to better recognize, understand and market to their consumers.
The Signal Platform enables our clients to:
- Onboard and connect their offline data into the digital marketing and digital advertising ecosystem.
- Link their offline and online data from digital applications such as websites, mobile apps, emails and digital advertising for better cross-channel measurement, advertising and marketing activities.
- Recognize their users across multiple devices and platforms, to better understand their customers, and to engage their users with more relevant messages.
- Distribute their data to their partners throughout the digital ecosystem.
You can find out more about us and our Platform here.
Information We Collect:
In order to provide the Platform, our clients must configure the Platform to collect data from users of our clients’ websites, mobile applications, advertising impressions, email campaigns, retail stores and other sources (“Data Sources”) that use our Platform. Signal does not have any relationship, contractual or otherwise, with the users of the Data Sources, the client maintains these relationships.
The Platform deploys various cookies and similar tracking technologies (See How We Collect Usage Data) to automatically collect certain information about your device when you visit or interact with Data Sources that use our technology (“Usage Data”) as well as information about how you interact with ads. This includes your IP address and certain unique identifiers that may be considered personal data in certain jurisdictions, including the European Economic Area.
We collect this information by assigning a random unique identifier (“UID”) to your device the first time you interact with a Data Source that uses our technology. The UID is then used to establish linkages between you and other information the client and Platform may have about you.
The information we automatically collect includes:
- Information about your device, such as the IP address and unique identifiers assigned to your device (e.g., iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID or GAID).
- Information about your online behavior, such as information about the activities or actions you take and content you view on Data Sources that use our technology, such as time spent on a web page, and whether you scroll or click on an ad or a web page, session start/ stop time, your referring website address, geo-location data, searches performed, and purchase history.
- Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it and the number of times you have seen the ad.
We do not collect any “sensitive” or “special categories of personal data” as defined under European data protection laws.
We may also enhance the Usage Data, with information collected from third parties, such as other web-based and mobile networks, exchanges and websites (“Partners”) or our clients (for example, they may upload certain “offline” data into the Platform). In addition, the information we automatically collect may be associated with profile information that we infer about you. This information may include, for example, hashed identifiers derived from other information (such as email addresses), mobile device IDs, demographic or interest data, and content viewed or actions taken on a Data Source.
Signal’s Tag Manager (Data Hub) itself [including the domain thebrighttag.com] does not have usage tracking about the on-page firing. With no tags deployed, Signal does not collect any information. When used by a business customer of Signal, Signal Data Hub will deliver the library containing the customer specified tags to the customer’s owned property. A customer may choose to use custom Signal tags to track information about the usage of their own properties. This first-party data is only accessible to the client that collected it and is never made available to other clients or to Signal itself for any other usage.
In order to monitor system stability and performance, Signal may collect some aggregated data about tag firing. This firing data does not include user IP addresses or any user-specific identifiers that could be associated with a particular individual. Other than data in standard HTTP request logs, all of which are deleted within 14 days of being received, and aside from the first-party use case described above, Signal does not collect, retain, or share any information about visitors to our customers’ properties, including page URLs visited.
How We Collect Usage Data
Cookies and Local Storage. Cookies and local storage are data files placed within a browser on a device when it is used to visit a website. Both cookies and local storage can be used to store device identifiers whenever you visit one of our client’s websites. Most browsers provide you with the ability to disable or decline cookies and local storage.
Web Beacons. Web Beacons are small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) that are included in our clients’ websites or emails.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with a website. The code is temporarily downloaded onto your device from our web server, is active only while you are connected to the website, and is deactivated or deleted thereafter.
SDKs and APIs. SDKS and APIs are programming codes that collect information about your interactions with mobile apps and websites. This code is installed on a device, typically within our clients’ applications that you choose to download onto your mobile device.
How We Use Your Information
- To provide the Platform to our Clients. Generally, we use the information we collect about you to help our clients to better understand their customers and prospective customers and help our clients better target and customize marketing, websites and content, and measure and optimize the performance of their marketing.
- To build various inferenced data segments (“Data Segments”). We may use the information we collect to help our clients build Data Segments related to, for instance, the industry you are in or the type of content you appear to be interested in. We use these Data Segments to help our clients, understand their own customers. The Data Segments also may be associated with UIDs, cookies and/or mobile device advertising IDs.
- To do “interest-based advertising”. We work with clients and Partners that use UIDs and associate them with cookies and/or other device identifiers such as hashed email addresses to help them target ads to you that are based on your offline interests, transactions or demographic information. This is often known as “interest-based advertising.” You can find out more about this type of advertising at the DAA’s website, located at http://www.aboutads.info.
- To do cross-device tracking. We (or Partners and clients we work with) may use the Usage Information – for example, IP addresses, hashed email addresses, and UIDs – to try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with providers that do this, in order to enable our clients to better target ad campaigns to common sets of users. For instance, a brand may wish to target customers that it usually recognizes on web browsers through mobile apps.
- To do “user matching”. We (or our Partners) may also use your information to sync cookies and other identifiers with other Partner and clients (“user matching”). For example, in addition to the UID’s a user may have been assigned in our system, we may also receive a list of UIDs our Partners or clients have assigned to a user. When we identify matches, we then let our clients and Partners know, in order to help them do any of the above, including enhancing their own data, to do interest based advertising or provide insights to other clients.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- To evaluate, operate or improve the Platform.
Cookies and Similar Tracking Technologies
How We Use Your Information
Analytics Providers, Ad Servers, and Similar Third Parties
We work with network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on our Websites, including pages viewed and the actions taken when visiting our Websites, to serve our advertisements on other websites, within mobile apps, and elsewhere online, and to provide us with information regarding the use of our Websites and the effectiveness of our advertisements. For example, if you view or click on an advertisement for Signal or one of our products, our service provider(s) may be able to tell us the advertisement that you clicked on and where you were viewing the advertisement. Our service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you and your visits to and activity on the Websites, as well as on other websites or online services.
We use a variety of service providers to perform advertising services. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit https://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or https://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.