We've also provided a section about the choices that you have with respect to "interest based advertising,", and we encourage you to read that section and exercise your "opt out" rights if you're inclined to do that. (But because interest based advertising leads to more relevant (and thus, less annoying) advertising, we hope you won't do that.)
Introduction and Background
We encourage consumers to learn about how information (including information we collect) can be used to market to them, and how to exercise their choices to permit or, if they prefer, to limit such marketing. We describe some ways consumers can exercise that choice or opt out of marketing in Section 6, below, titled Consumer Control & Opt Out Options .
1. Our SDKs: Information We Collect and Services We Provide
We refer to the information we collect from our SDKs as the "SDK Information ." The SDK Information includes (or may include) the following:
Information Collected About End Users by Our Web SDKs
• Web pages visited that have implemented the SDK , and information about those visits (e.g., session duration, time-stamp, referring URLs)
• What newsletter emails an End User has been sent
• Information about End User's transactions and interactions with apps and websites
• IP address, from which geographic location may be inferred, as well as system configuration information
• Email address which we may ( in our discretion ) hash or otherwise deidentify
• Information about an End User's browser, such as, browser language type and version of operating system (e.g., Android, iOS); network provider; language setting; time zone
• A unique cookie identifier, which may uniquely identify an End User (such as in de-identified or anonymous form). These cookies may be associated with other Information, including with Data Segments, which we describe in Section 3.
Information Collected About End Users by Our Mobile SDKs
• When permitted by the operating system, NewsletterHut may check to see if the device has specific applications installed, based on a limited list, for purposes that include attribution, relevancy of ads, and relevancy of notifications related to those applications.
• Purchases made within an app.
• Information about End User's transactions and interactions with apps and websites
• Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs ("Mobile IDs"). These Mobile IDs may be associated with other Information, including with Data Segments.
• Precise Location information, generally an End User's lat/long data (i.e., GPS-level data) or WiFi information, which we may associate with Mobile IDs, and which may be collected whether or not an app is in use.
• Email address, which we may (in our discretion) hash or otherwise deidentify.
• IP address as well as system configuration information
• Information associated with or related to devices, such as device type (e.g., mobile, tablet); type and version of operating system (e.g., Android, iOS); network provider; mobile browser (e.g. Safari, Chrome, etc.); language setting; time zone; and network status type (such as WiFi).
As noted above, we refer to all of the above collectively as the "SDK Information ."
2. How We Use the SDK Information
We use the SDK Information to provide a variety of Services to our Clients. This includes:
• To Provide Our App and Website Services. We use the SDK Information to offer and support app and website features provided through the SDKs, including those related to newsletter emails. This includes, for instance, providing customer, technical and operational support for these features, detecting and protecting against errors, fraud, or other criminal activity; resolving disputes and enforcing our EULA and other rights we may have. It also includes analyzing, customizing, and improving the features we offer Clients.
• To provide information and analytics to our Clients about the use of these app and website features provided through the SDKs, or to help app developers and website operators create or enhance user profiles.
• To create inferences about End Users categorized into "Data Segments" or to help Clients do so. For instance, if SDK Information indicates that a particular device is frequently seen at restaurants, we might categorize a user for targeting of local restaurant offers. Or, if a user is frequently seen at sports stadiums, we might categorize the user as a "Sports Fan."
• To develop and use "predictive models" - data models that try to predict End Users' potential future behavior and interests on a per-device basis or across devices
• To analyze ad performance, for instance, by attributing End Users' app installations, web visits, or store visits to ad campaigns.
• Sometimes, the SDK Information may be used (by us or ad and data platforms we work with) to resolve identities across multiple devices, such as to match IP addresses or hashed emails to link an End User across (for instance) browsers, mobile devices, tablets, set top boxes, or other devices.
• Sometimes, the SDK Information may be combined (by us or ad and data platforms we work with), to perform any of the above functions, or other advertising, marketing or analytics services. Or, we may aggregate and create data "models" to do this - creating algorithms in order to predict certain trends and things that different End Users might have in common, for instance.
We, or ad and data platforms we work with, may deploy online cookies to track users across websites, or to associate users (and these cookies) with Mobile IDs. We or they may do this to resolve user identifies across platforms, and to better or more accurately target relevant ads to users (such as to a brand's customers). You can learn more about cookies and similar technologies, such as web beacons and SDKs, in the Section titled "Cookies, Pixel Tags and SDKs ." We may also "append" or combine certain SDK Information (such as hashed email addresses) to other information provided by third party data providers, to learn more about End Users or to provide advertising and analytics services.
3. How and Why We Share the SDK Information.
To Provide Services to Websites and Apps Using the SDKs
• We share the SDK Information with service providers, contractors and other companies to fulfill your orders, operate our business, communicate with you and make available our Services and this Website. These service providers may help us perform any of the activities set forth in Section 2. For instance, we may share certain of the information we collect or receive with companies that help us with billing and payment, marketing, advertising and email marketing,
• data enhancement (e.g., to provide more relevant offers), website hosting, technology and customer support, web and marketing analytics, anti-fraud or security operations, and other operational, marketing or business support.
• We likewise may share the SDK Information or Data Segments we create with website operators and app developers (for instance, related to newsletter emails delivered ) for their advertising, analytics, or other purposes.
To Provide Services to Marketers, Advertisers and Platforms They Work With
We also share SDK Information to provide or help us to provide advertising and marketing services as we have described in Section 3, including as follows:
• With advertisers and their marketing providers, so they may provide targeted content and advertising to you on websites and mobile applications With other third parties that target advertising. For those familiar with the online ad ecosystem, these may include demand-side and supply-side advertising platforms, data management platforms, advertising agency trading desks, proximity solution providers, and other advertising technology providers, so they may provide targeted content and advertising to End Users and others on third-party websites, mobile applications, and other advertising mediums (push notifications, direct mail, display media), and so that they may measure the effectiveness of this marketing.
• Similarly, we may work with service providers who, to enhance consumer privacy, use a non-human readable "hashed" version of Information such as an email address when sending advertising offers by email or display advertising (which may be linked to a cookie as described above).
• Sometimes we provide information (such as IP address, but excluding precise lat/long coordinates) to third party platforms to help advertisers identify common users across different devices or browsers - for instance, to identify a common set of users on both mobile devices and tablets, as well as the web.
The processes we've described above often involves cookies or similar technologies, which may be associated with other information about you, e.g., your interests, demographics or transactions. This is known generally as "Interest-Based Advertising." We encourage users who are interested in controlling or learning about this type of "interest-based advertising" to go to Section 6, titled "Consumer Control & Opt-Out Options , or go to this this page operated by the online ad industry trade association.
We may also share the SDK Information with third parties:
• If an End User or Client requests or authorizes
• If the disclosure is done as part of, including as part of due diligence for, a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, any information we have may be one of the transferred assets) or in the event of bankruptcy
4. How we Use and Share Information Collected on the NewsletterHut Website(s)Website Information We Collect
• Volunteered: You may share information with us on the NewsletterHut Websites when you request information from us, fill out a form on our website, or interact with us in other ways. This information may include personal information, such as your name, email address, and other contact information.
• Passively Collected (e.g., Cookies and Unique IDs): We use automated mechanisms, such as cookies, pixels, and other locally stored objects (such as "IndexedDB)") that we associate with unique identifiers in order to keep track of visitor interactions with the NewsletterHut Websites. (You can learn more about these technologies below in the Section titled "Cookies, Pixel Tags and SDKs")). We may use third party-services such as Google Analytics, in which case those third parties gather information such as your IP address, browser type, the webpage from which you came to our website, and the times of your access to the NewsletterHut Website. In addition, as you browse our website, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our display advertising partners may then help us retarget ads to you on other sites based on your interactions with the NewsletterHut Website. To "opt out" of having your information used to tailor ads to you in this way by third party ad platforms that we may work with or provide data to, please review the Section below titled "Consumer Control and Opt Out Options" to learn how to opt-out of these services and instead receive generic, non-tailored ads.
How We Use the NewsletterHut Website Information
In addition to the uses described above, we use the NewsletterHut Website Information (alone or in combination) to provide, market, and operate the NewsletterHut Websites and Services. Among other things, by collecting the NewsletterHut Website Information, we are able to
• Maintain and offer access to the NewsletterHut Websites and Services and optimize how they're offered to our Clients.
• Send information about our products and services, including marketing communications.
• Respond to your questions, concerns, or customer service inquiries.
• Customize the content and advertising you see on the NewsletterHut Websites, across the Internet, and elsewhere.
How We Share the NewsletterHut Website Information
We may share the NewsletterHut Website Information as follows:
• As part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence).
• With our corporate affiliates.
• With third parties that help us to provide the NewsletterHut Websites or Services, such as entities that help us make the NewsletterHut Websites or Services available and functional (such as hosting services); entities that help us make available or transmit any information we hold (such as helping us send emails, process payments, and manage customer information); and entities that help us (including our contractors, agents, and affiliates) provide technical, customer, billing, administrative, event planning, marketing or operational services to us or our Clients.
• When required by law or in response to lawful process, such as a subpoena, or to cooperate in good faith with a request from a government or law enforcement agency or official.
• If we believe sharing the information may prevent physical, financial or other harm, injury or loss; or we believe is necessary to protect our, or any other person's or entity's, interests; or in connection with an investigation of suspected or actual unlawful activity.
• We also may disclose your information under circumstances not mentioned here with your prior consent.
5. Cookies, Pixel Tags and SDKs
• Cookies and Pixel Tags.
• Mobile Device Identifiers and SDKs.
We may use or work with partners who use mobile SDKs (including our own SDKs, which are described in more detail in this Policy) to collect information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and information related to how mobile devices and their users interact with our Services and those using our Services. The SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. We may use this technology, for instance, to analyze or measure certain advertising through mobile applications and browsers based on information associated with your mobile device. If you would like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the below Section titled "Consumer Control and Opt-Out Options ."
As described in Section 4 our Clients or Partners may use the above technologies (sometimes, in combination with each other or other data such as IP addresses or hashed or de-identified data files) to coordinate identifiers across platforms, browsers or devices, to more efficiently analyze or target advertising.
6. Consumer Control & Opt-Out Options.
In most cases, consumers have control over whether or not they would like to receive relevant advertisements and marketing email from our Clients.
• Opting out of NewsletterHut's newsletter emails
Each newsletter email contains an "Unsubscribe" link, which, when clicked, instantly unsubscribes the user from receiving further emails from NewsletterHut on behalf of it's Clients.
Your choice to unsubscribe from NewsletterHut's emails will not affect promotional material delivered from other sources.
• Opting Out of Online Interest-Based Advertising
You can opt out of many of the platforms and service providers that facilitate online interest-based advertising by visiting the Digital Advertising Alliance's consumer education and opt-out page, at http://www.aboutads.info/. This type of opt out is cookie based, which means that if you replace or upgrade your browser, or delete your cookies, you will need to opt out again. Opting out in this way will not prevent you from receiving ads - it will just make the ads you see less customized to you.
• Additional Choices
Advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for retailers, applications and websites to learn more about their privacy practices.
You may opt not to receive promotional emails from us by contacting us as indicated below or by following the "unsubscribe" instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.
7. Data Access and Retention
8. Data Security
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect information contained within our systems from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information and Non-Personal Information.
9. Third Party Websites and Apps
10. Contacting Us
Anything on your mind?