Insightful Media Privacy Policy

Insightful Media is a buying platform. It buys advertising from ad exchanges, supply side platforms, ad networks, publishers and sites. Insightful Media provides online media buying services via its performance network to its advertiser and agency clients. In doing so we utilise technology to help ensure that our client’s adverts are shown to the most relevant users on the most relevant websites. Generally, an internet user’s computer comes into contact with Insightful Media’s technology when a user visits a website, or views an ad, connecting to our technology platform. As a general rule of thumb, advertisers pay more for relevant and targeted advertising which supports online publishers in continuing to provide us with the free online content that we all love.

Insightful Media currently uses advertising technology provided by Turn. Turn advertising technology collects data that is not personally identifiable (non-PII) about the websites and apps that an individual interacts with, and the advertisements a browser or app displays. This information may include non-PII device-specific identifiers provided by third parties. An individual may encounter Turn advertising technology when:

• Turn or a business partner purchases online advertisements on a website that the individual visits or an app that the individual uses.
• A Turn business partner places one of Turn’s web beacons on a website that the individual visits or uses.
• An individual interacts with an app from which Turn collects data.

Turn advertising technology also offers data management services to business partners via Turn’s data management platform (DMP). The Turn DMP enables Turn’s business partners to collect, store, and analyse non-PII about their audiences. Turn’s business partners may use the DMP and Turn’s data collection tools to develop and name custom data segments. Turn does not exercise control over the manner in which its business partners label their custom data segments in the DMP, but as applicable, Turn contractually requires that its business partners using the DMP adhere to self-regulatory codes offered by the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), and/or certain other industry standards. Turn also contractually prohibits its business partners using the DMP from bringing PII or sensitive non-PII audience data into the DMP.

Personally Identifiable Information

We don’t collect or use Personally Identifiable Information (“PII”) via our Technology. For sake of clarity, Insightful Media does not collect or use your name, address, phone number, e-mail address, Social/National Insurance Number, credit card information, or anything else that can personally identify you.

Sensitive Personal Data

We don’t collect any data relating to or infer your racial or ethnic origin, political opinions, your health, religious or philosophical beliefs, trade union membership or sex life.

Non-Personally Identifiable Information

We collect Non-Personally Identifiable Information (“Non-PII”) via our Technology which may include but is not limited to your IP host address, date and time of ad request, pages viewed, business partner web pages have been viewed by a browser or application; search terms entered on business partner websites; referring and exit pages; and the date and time an advertisement was viewed. In certain instances, we may collect and match this non-PII across devices, browsers, or applications for the purposes of providing more relevant advertising.

Cookies and Web Beacons

Our technology uses cookies in conjunction with Web beacons in order to help make the online advertisements you see more relevant to you. We also use cookies and web beacons to understand your browsing and buying activities so that we can measure the success of our own and our clients online advertising campaigns.

Cookies are small text files that web servers typically send to users’ computer when they visit a website. Cookies are stored as text files on users’ hard drive, and can be accessed by web servers when the user returns to a website or goes to another website. Cookies are often used by companies to collect and send information about a user’s website visit – for example, number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. This information helps companies improve a user’s online experience in many ways: for example, by allowing companies to monitor website performance, make the website easier to use, measure the effectiveness of their promotional placements, and tailor their website to better match a user’s interests and preferences. Cookies cannot be used to access any other data on a user’s hard drive, or to personally identify them. Users who prefer not to accept cookies can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive.

Turn and Insightful Media uses the non-PII it collects to identify the audience most likely to respond to a particular ad, to serve those ads, and to analyse trends. This helps support the online advertising ecosystem, app and website developers, and consumers by supporting content and delivering more effective advertisements. Turn may also aggregate this information and share it with Turn affiliates and business partners.

Turn advertising technology enables Insightful Media to use advertising segments to deliver relevant advertising. An advertising segment is defined by non-PII attributes, which often includes combinations of information such as geography, age range, gender, activities, and/or interests.

Turn customers may use non-sensitive health-related segments to help deliver tailored advertising. For example, Insightful Media may deliver tailored advertising regarding healthy living because a browser visited websites that are focused on health-related topics such as yoga and healthy eating. Click here for a list of health-related segments that are made available to Turn’s business partners by third-party data providers.

Turn and Insightful Media may collect and use the information and the data segments described above for cross-app advertising, i.e., advertising across browsers and apps on a single device, as well as cross-device advertising, i.e., advertising across multiple devices. Turn also collects and uses cross-app and cross-device information for ad delivery and reporting purposes. As described elsewhere in these privacy guidelines, Turn and Insightful Media does not collect PII via its advertising technology, including across apps and devices.

Turn uses certain techniques to enable its advertising technology to serve meaningful advertising content on behalf of its customers and business partners across apps and devices, including cookie and ID Syncing and similar practices.

All of the user data collected by Insightful Media is stored only in aggregate form meaning that information about a specific user cannot be retrieved. Even so we maintain physical, electronic, and administrative safeguards to protect all our data from accidental, unauthorised or unlawful access, use, modification, disclosure, loss, or destruction. The data is kept on a secure server and we restrict access to the data solely to authorized users. No security measures, however thorough, are perfect and there can be no absolute assurance of security and therefore, we cannot and do not offer an absolute guarantee or warrant the security of the information we possess.

The security of information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to the use of firewalls and encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect Non-PII information, we cannot guarantee its absolute security. If you have any questions about our security practices, please send an email to us at lee@insightfulmedia.ie

As described above, Insightful Media stores only aggregated data on its servers. We may disclose Non-PII information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.

Also, in the event that Insightful Media is merged into another company, or another company acquires all or substantially all of Insightful Media’s assets, including, without limitation, in the event of bankruptcy, all data compiled or owned by Insightful Media may be among the items transferred in that transaction. In such event, all the data will continue to be governed by this Policy.

Turn removes non-PII associated with a Turn ID from its ad-decisioning database if more than 30 days have passed since it has seen any activity associated with the Turn ID, or has delivered advertising to a computer or device associated with the Turn ID. However, if Turn has transferred non-PII from an inactive Turn ID to an active Turn ID, the non-PII will not be deleted from the set of information associated with the active Turn ID. Turn may retain this and other data it collects in other formats for as long as necessary for reasonable and legitimate business purposes including fraud prevention, audit and legal compliance, and billing disputes.

Non-PII associated with a Turn ID may be stored in Turn’s DMP indefinitely. This information may be used to create advertising segments but is not used to deliver tailored advertising to a specific Turn ID.

Insightful Media adheres to the EDAA’s European Self-Regulatory Initiative for Online Behavioural Advertising (OBA). If you’d like to opt-out from having Insightful Media collect your Non-PII via our Technology, please click here. When you opt out, we will place an opt-out cookie on your computer. The opt-out cookie tells us not to collect your Non-PII to tailor our online advertisement campaigns. Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer or Internet browser, you may need to renew your opt-out choice. For more information regarding opting out from behavioural advertising please click here.

In accordance with the codes set out by the ASAI and the CAP, the services of Turn and Insightful Media are not intended for persons under 16 years of age. Insightful Media’s performance network products and services are not developed for or directed at children. We do not knowingly solicit or collect any personally identifiable information from children under the age of 16 nor do we knowingly market our products or services to children under the age of 16.

We may revise this Policy at any time. Any changes and/or updates to the Policy will be updated directly on this page. We encourage you to visit this page periodically to review our current Policy so that you will always know what information we gather and how we may use that information. In the event we make any material changes to this Policy we will advise our clients in advance.

If you have any questions or complaints in regards to this Policy, Insightful Media’s privacy practices or complaints about OBA data or its use, please contact us at the following email and we will be more than happy to clarify and assist you in any way possible: lee@insightful.ie

Alternatively you can contact us by phone:+ 01 703 0406,

or by post at:

Insightful Media,

39 Clarendon St

Dublin 2, Ireland