Trilogy Analytics is an advertising agency owned by Trinity Broadcasting Texas, a global media group that includes multiple broadcasting networks and digital media companies around the world. As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact, and we encourage you to read the following privacy policies.
Last Updated June 12,2024
Scope This Website Privacy Policy (the “Privacy Policy”) applies solely to information collected by Trilogy Analytics (“TA”) on this website (the “site”). This Privacy Policy provides information about how and why TA collects and uses the information we obtain through this Site.
For information on TA’s range of services, how we use data across our different services, and your options, please refer to the General Services Privacy Policy located below.
For information on TA’s online and cross context behavioral advertising activities and how to opt out of having data processed for online behavioral advertising purposes, see the TA Online and Digital Services Privacy Policy located below.
Links to Third Party Sites
This Privacy Policy does not apply to the practices of third-party sites including, but not limited to, client and affiliate websites, applications and websites on which we may place advertisements, and any third-party websites you may link to from our sites. TA does not endorse or make any representations about these third-party sites or applications, or any information, software, products or materials found there. We encourage you to review the privacy policies of these sites and applications to understand their data collection and use practices.
Information Collection
We collect two types of information from and about visitors to this website: information that you provide or submit, and tracking data that is collected automatically when you navigate the website. Tracking data may include things like the Uniform Resource Locator (“URL”) of the site you visited before coming to this site, the URL of the site you visit after leaving our site, the type of browser you are using and your Internet Protocol (“IP”) address. We, and/or our authorized third parties, may automatically collect this information when you visit our site through the use of electronic tools like cookies or pixel tags, as described below.We use tracking data to administer the Site, analyze trends, gather demographic information, troubleshoot, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized third parties to measure the overall effectiveness of our online advertising and content.
Information Use
TA uses the information we collect at this site to fulfill your requests, respond to your inquiries, provide TA news or updates, and to understand the audience for our site. We may also use your information to make our sites easier for you to use and to inform you of service and product updates, whitepapers, new products, market research opportunities and other related information from TA, or to send you promotional messages regarding various TA projects, products, and services.TA uses tracking data to analyze trends, administer the site, track users’ activities on the site, help us understand the parts of our sites visited most often and gather aggregated demographic information for use in improving the site’s performance. TA may also obtain personal information from you if you apply for a job with us. This data would include your name, email address, mailing address, employment history and any other information contained in your resume/C.V. that you submit. We may use this information to review your application for employment.
Information Sharing and Disclosure
TA may share your information with our affiliate companies and service providers for the purposes described in this policy.We may disclose your information as required by law, court order or other valid legal processes or in connection with the consolidation, sale of or other transaction related to our business. We also reserve the right to disclose your information if we believe in good faith that disclosure is necessary to protect our rights or safety of any person, investigate fraud, or respond to a valid government request.
Choices
Opt-Out of TA Corporate CommunicationsEven if you choose to opt-out of our communications, TA will retain and use your information to comply with our legal obligations, resolve disputes, enforce our agreements and to maintain a record of your opt-out. You may also still receive transactional emails, such as registration confirmation, product updates and responses to direct requests you have made.
Cookies
Cookies are small text files that store data using your web browser to enable websites and marketing companies to recognize you and to associate your browsing activity with other data. We, and our third-party service providers who assist with managing our site, use cookies, web beacons, pixels, and similar technologies on our site to track use of our Site in order to improve its performance, ensure we are providing content that is of interest to our site visitors, and to make our Site more user-friendly. We may also use cookies for cross context behavioral advertising. What this means in practice is that we might use cookies to help determine which ads you see online, by logging your visits to many advertiser / brand websites, and then showing you ads for similar products and services.
Types of Cookies used on our Site
Performance Cookies: These cookies collect information about how visitors use our site for web analytics purposes, for instance which pages visitors go to most often and error messages received. These cookies are only used to improve how our site works and your experience on our site; they do not track your browsing activity on other websites. By using our site, you agree that we can place these types of cookies on your device.
Functionality Cookies: These cookies allow our site to remember choices you make (such as your username and password, language preference or the region you are in) and provide enhanced, more personalized features. These cookies may also be used to remember changes you have made to text size, fonts and other personalization. They may also be used to provide services you have requested, such as keeping you logged in to your account as you browse the internet. These cookies do not track your browsing activity on other websites. By using our site or by signing up for an account with us, you agree that we can place these types of cookies on your device.
You may be able to adjust your browser settings to manage your cookie preferences, such as setting your browser to notify you when you receive a cookie and give you the choice to decide whether or not to accept it. If you reject cookies, you may still use our site, but the functionality of some areas may be limited.
Below are links to information about managing your cookie preferences in common browsers:
Content Sharing Features
Our site may include social media sharing features, such as LinkedIn and Twitter buttons, and may set a cookie to enable the feature to function properly.
These features may collect your IP address and which page you are visiting on our site. Social media features are governed by that social media company’s privacy policy.
DATA RETENTION.
We retain the information we collect for only as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.
SECURITY.
TA uses commercially reasonable safeguards to protect personal information against loss, misuse or alteration and to maintain the integrity and security of all information collected through the site. These include technical, physical, and administrative security controls.
YOUR RIGHTS REGARDING PERSONAL DATA.
You may have the following rights under applicable privacy / data protection laws in relation to your personal information, including:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of personal information we hold about you.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. In many cases we do not have the technical ability to correct data, and so will delete the incorrect data instead.
Request deletion of your personal information. This enables you to ask us to delete personal information. There are some limited cases where, as allowed or required by applicable laws, we may refuse to delete data. We may also anonymize data so that it cannot be related back to you instead of deleting it. Even if we have deleted other data relating to you we will maintain a record that you have opted out so we do not contact you in the future.
Object to processing (opt out) You may request that we do not use your personal information for direct marketing purposes.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. In general, such requests will be treated as deletion requests.
Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our privacy officer at privacy@triumphanalytics.ai.
INTERNATIONAL DATA TRANSFERS. This site is based and hosted in the United States. This means that when you submit personal information to the site or we collect tracking data at the site, it will be processed in the United States and may also be accessed by overseas technical support teams. Your data may also be shared with our affiliate companies or with our service providers. also be shared within the TA Group or with our service providers.
Whenever we transfer personal information out of the European Economic Area (“EEA”), we transfer data subject to specific contracts approved by the European Commission, which ensures that personal data receive the same protection it has under European privacy laws.
Do Not Track / Global Privacy Control (“GPC”) Some browsers offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to websites about the user’s browser DNT preference setting. Historically, there were multiple technical standards, and they were not widely adopted by websites and data companies. As of December, 2023, the industry is in the process of transitioning to the Global Privacy Control (“GPC”), a new browser-based DNT option that will be implemented during 2024. TA will apply GPC signals when the new system is established.
Children’s Privacy This site and the services we provide are intended for general audiences, and is not intended for use by persons under the age of 16. If we learn that we have inadvertently collected personal information from a child under the age of 16, we will delete it. If you believe that we have collected personal information from a child under 16, please contact us at privacy@triumphanalytics.ai.
Updates to this Privacy Policy We reserve the right to modify this privacy statement at any time. Note the date of the most recent update at the top of this page.
Contact Us To ask questions about TA’s Privacy Policy or to request more information on TA’s privacy practices, email us at privacy@triumphanalytics.ai Or send correspondence via mail to:
Triumph Analytics
Attention: Privacy Officer
3600 Heritage Pkwy, Suite 200
Fort Worth, TX 76177
Last Updated June 6, 2024
INTRODUCTION
TA is a business-to-business (B2B) marketing technology and data company that uses software and information about consumers to help advertisers reach selected audiences via online or in-app ads, email, direct mail, telemarketing, SMS, connected TV, or any other channel where advertisements are presented. As part of a global media company, TA is affiliated with multiple, separately branded companies that have their own privacy policies that comply with applicable laws.
TA collects and uses data about individual consumers for the limited purpose of helping to identify or predict the types of advertisements most likely to appeal to them, or by communicating directly in response to a request. TA owns and operates multiple webpages, contact forms, and social sites, and many of these are standalone sites associated with client advertising campaigns. When data is collected through these sites, we always provide a link to this privacy policy.
We do not, however, collect data indiscriminately. We limit the types of data we collect to what is relevant to your interests, purchase intent, and recent engagement. Our data comes from (a) data that you have consented to be used for marketing purposes, (b) our own first-party data, (c) data from our cookies which are recognized when you visit websites where our pixel is in use, and (d) data purchased or licensed from reputable third parties.
TA provides a range of services, as described below, and the way each works is different. But in general, the data we collect is used to match people to advertisements that are likely to interest them. We use data, software, and creative ingenuity to help advertisers achieve higher-than-average rates of response—that is, people clicking on an ad or making a purchase.
TA uses a marketing technology platform that serves ads across major broadcasting networks and a wide range of digital channels. This platform serves three functions: (1) we may load client data there be analyzed and “activated” into advertising on different marketing channels (email, online, smart TV, etc.); (2) client-owned data can be matched with TA-owned data in order to better inform marketing decisions without disclosing personally identifiable information; and (3) activation of marketing campaigns and advertisements sent to people known to TA but not known to the advertiser to help generate new business for the advertiser. TA does not release personally identifiable data to its clients – it’s always strictly controlled, and whenever client data is shared for analysis, it’s done anonymously and kept separate from TA data. These services are further protected by nondisclosure and data processing agreements that recognize applicable laws.
This General Services Privacy Policy describes each of the different types of services TA provides, which are divided into two main categories:
When we act as a service provider, we follow the client’s privacy policy because the data we process in that role belongs to our client and we handle that data only at the client’s direction and acting exclusively on their behalf. When TA collects data directly from consumers or obtains data collected by third parties for our own business purposes, we are responsible for how such data is used and shared, and for giving effect to individuals’ privacy legal rights.
For all of our services the overall purpose of our data collection is the same—to match advertisements to people who have a propensity to engage with them, and ultimately to increase sales for our clients.
All services may include some amount of “lookalike modeling,” where we use data about known purchasers of a product or respondents to an ad to identify attributes that suggest a propensity to respond. These attributes are then used to find similar audiences predicted to be interested in the product or service being advertised. Many of our services include a component of “cross context behavioral advertising,” which means that TA has matched consumer data belonging to our clients with data from other sources to better tailor advertising to individual consumers.
We do not provide services that include ads with illegal or adult content, nor do we advertise on adult sites or collect data about what adult sites people visit. In fact, browsing history is only collected at certain websites, so it is never a complete history of online activity. We do not knowingly collect or sell personal information from children under 16. If we learn that we have collected personal information from a child under the age of 16, we will delete it immediately. We do not knowingly facilitate any advertising that is exploitative, discriminatory, hateful, deceptive, or abusive. We do not allow our data to be used to make impactful decisions about individuals, such as eligibility for credit, insurance, housing, employment, or education. Our data is used exclusively to match people to ads that may interest them.
The types of data we use are the same across all our services:
Sensitive Data.
Some privacy laws define certain categories of data as “Sensitive Data.” Depending on the specific law, this category can include government-issued identification numbers, such as US social security numbers, credit card numbers, or a driver’s license number. TA does not collect or store sensitive data. Our client data processing agreements specifically prohibit this, and we have automated QC processes designed to identify and kick out data flagged as suspicious.
Our sources of data include:
Recipients of our data include:
You will find more details in the sections below describing each of our services.
SERVICES WHERE TA ACTS ONLY AS A SERVICE PROVIDER
Where we perform services exclusively as a service provider or data processor, the data that we handle belongs to our advertiser client. In most cases this data will be put in TA’s care by the advertiser in order to use our marketing software and tools. Advertisers may also ask us to collect data on their behalf through various means, including direct collection from individuals, at a web page or sign-up forms we host for the advertiser, via cookies or other online tracking mechanisms or potentially even third-party sources. When we collect data as a service, all of the data we collect belongs to our client and is governed by the client’s privacy policy. In some cases, TA will collect data through TA owned and operated websites, pages, and forms. When we do, the data we collect is governed by TA’s privacy policy.
Who are TA’s Clients? Our clients are companies you interact with every day. Consumer products brands, retailers, financial institutions, travel, dining, and hospitality providers, education providers, healthcare advertisers, and companies specializing in the film and entertainment space. Most often we work with them directly. Occasionally, we partner with other advertising agencies who may represent the client. In either case our mission, and the purpose for which we collect, use, and share personal data, is to help these companies use their marketing resources more efficiently by matching offers to the people who are most likely to be interested in them.
Database Services. TA performs services for some clients that include database development, data processing, analytics, predictive modeling, and audience segmentation. TA also provides consulting services. In some cases, TA may maintain a “database of record” for a client, meaning that the client has outsourced the maintenance of its primary customer database to TA. In such cases, TA may collect data directly from individuals, but handles the associated personal data exclusively as a service provider and does not do anything with the data outside the scope of the specific services that we have been hired to perform.
Email Services. Clients may engage TA to send email to their existing customers on their behalf. For instance, if you have given a retailer your email address, we might send commercial or transactional messages from that retailer, everything we do is at the advertiser’s direction and subject to the terms of their privacy policy.
Call Center Services. Clients may engage TA to receive calls on their behalf, or to make telemarketing calls on the client’s behalf. When we perform these activities as a service provider, we use client-owned data and perform our services in line with the terms of the client’s privacy policy.
Product Fulfillment Services. Clients may engage TA to provide warehousing and product fulfillment services on their behalf. When we perform these activities as a service provider, we use client-owned data and perform our services in line with the terms of the client’s privacy policy.
CRM Services. We use our software, data and know-how to help our clients better organize and manage their own customer data, so they can become more effective communicating with their customers.
Website Personalization. We use pixels, cookies, and other online data collection techniques to help personalize a user’s website experience. For instance, we may use data collected at an advertiser’s website to determine which language is used, what content and ads are displayed, and to remember settings like font size or page display.
Audience Segmentation. We use cookies and pixels to help store data such as IP addresses, logfile data, ad impression data, mobile advertising identifiers (e.g., Apple mobile advertising ID or Android advertising ID) and other pseudonymous identifiers. When providing these Services, TA acts as a service provider for our clients and processes data according to the terms of our service agreement. Audiences can be sourced from 1) the client’s data, 2) TA owned data assets, or 3) third party data TA has licensed.
SERVICES WHERE TA COLLECTS AND USES DATA ON BEHALF OF TA OR OUR CLIENTS
The Heartland ID Graph (ID Graph) is what we call the data related to consumers that TA collects or obtains and uses on its own behalf. Our ID Graph uses first-party data sourced across our affiliate companies including two major broadcasting networks and multi-media organizations. This data represents the majority of customer interactions (donor transactions, app registrations, VOD viewing history, website visits, form submittals, direct mail response, surveys, newsletter signups, campaign conversions, ecommerce transactions etc.). It also includes connections to third-party data sources to provide near real time insights that inform specific ad placements.
TA uses the most up-to-date data we can obtain. Our proprietary software, machine learning, and AI tie all these sources of data together which enables us to make very complex decisions about which person is most likely to respond to a specific ad at any given time, and then deliver that ad on the preferred channel of choice.
Fully identifiable personal data (such as email address, name, or postal address) in the ID Graph is in all cases collected first when an individual has given us consent by accepting the privacy policy and terms of use under which it is governed. This permission is generally provided at a web page that includes opt-in or opt-out choices defined in the privacy policy. This data is then augmented with other data obtained from other sources to enable us to make the best possible decisions about which ad to show to which person at which time.
We may also use data from the ID Graph for analytic purposes to evaluate overlapping segments and match rates to client data. When we do, it’s performed in an anonymized test environment compliant with client data processing agreements.
Acquisition Email. For this service, we send client advertising by email to people who have consented to receive commercial email. These emails all comply with applicable laws (including the U.S. federal CAN SPAM Act) pertaining to the sending of commercial email and include opt-out links so that recipients can request not to receive future emails. We do not sell this data to our clients. However, when someone responds to an ad and engages with the advertiser (purchase, download, signups etc.), that data becomes the advertisers governed by their privacy policy.
Acquisition Email services for a particular client usually begin with an analysis of a sample of that client’s existing data in order to create a profile of the type of individual who is most likely to respond to a particular offer. We then look to the ID Graph to find people who share those attributes but who are not already existing customers ofour client and send offers or advertisements to those people.
CRM Services. This service consists of loading a TA client’s customer data onto a secure TA controlled server, and then using our software to compare the client’s data with data in the ID Graph. In most cases, we have more data points about an advertiser’s customers than the advertiser has. We use that data to predict which customers are most likely to respond to a particular ad campaign.
Online/Cross Context Behavioral Advertising. The data we use for Online/Cross Context Behavioral Advertising (OBA) is tied to a cookie ID, a mobile advertising ID, or other data related to a specific device, like a computer, smartphone or smart TV, or to a browser on that device. TA may, by means of matching cookie IDs and other unique identifiers, be able to link OBA data to other, fully identifiable data.
When you visit different sites on the internet, different companies place cookies on your device, and use these to obtain information about the sites you visit, the ads you respond to, and the online purchases you make. Through a process known as “cookie matching” different companies (data sharing partners) can either sell or exchange different bits of this data. By stitching together bits of data from different sources, we are able to create a rich and up-to-date dataset that enables us to make predictions about which ads are most likely to appeal to a specific person or audience group.
Optimization and Analytics Services. These services help our clients manage their digital advertising programs. For example, we may help these businesses customize your experience when you visit their website, generate leads and manage their keyword search advertising programs. We undertake these activities on behalf of our customers, subject to their respective privacy policies.
Opting-out of Online Behavioral Advertising and Data Collection by Our Cookies
To learn more about Online Behavioral Advertising (also called interest-based advertising or cross context behavioral advertising), analytics services and your choices, including how to opt-out of some interest based advertising, visit https://www.youronlinechoices.com, https://youronlinechoices.eu/, the DAA Consumer Opt-Out Page, NAI Consumer Opt-Out Page and Google’s information page.You can also refuse or disable cookies already stored on your browser as follows:
You can also refuse or disable cookies already stored on your browser as follows:
YOUR PRIVACY RIGHTS
Privacy laws around the world give individuals different versions of the rights described below. TA allows any person to exercise the following rights no matter where they live. TA will not discriminate against you for exercising your privacy rights. Prior to fulfilling a request for a copy of data, TA is required to reasonably verify your identity, which we generally do by sending a verification link to the email address associated with your data, or by reading a cookie directly from your browser. Under applicable laws, you can use an authorized agent to make a request on your behalf, but that agent must be able to complete our verification process in order to demonstrate that they have been authorized to make the request. For data in our ID Graph, verification will require access to the email address that is submitted with your request. For data that is linked to cookies but not integrated into our ID Graph, access can only be provided to the browser where that cookie is present.
To exercise your rights with respect to data in the ID Graph by either you or your authorized agent click, please contact us at privacy@triumphanalytics.ai. You may also use the opt-out link included in any commercial email we send you, or respond STOP to any SMS marketing message we send. If you have any problems using these mechanisms you can contact privacy@triumphanalytics.ai for more help.
You also have the right in many countries to contact a privacy or data protection authority if you believe we are not complying with privacy laws, and we have not been able to resolve the situation to your satisfaction. Many countries have a dedicated privacy / data protection authority; in the United States you can file a complaint to the U.S. Federal Trade Commission or your state Attorney General.
WHERE WE PROCESS DATA
TA is headquartered in the United States, and the majority of our services are performed in the United States. When you provide data to TA, you consent to its processing in the United States. Our online services may potentially collect data relating to residents of any country, but the majority of the data in the ID Graph relates to residents of the United States. We may also handle as a service provider client-owned data that originates from any country. In all circumstances we are compliant with the laws of those countries.
DATA SECURITY
TA uses commercially reasonable, industry standard practices to protect data. These include technical, physical, and organizational controls designed to prevent loss or unauthorized access to data. Our technology partners security measures are audited every year by an independent third party, and we are constantly evolving our approach to security to keep pace with emerging threats.
HOW TO CONTACT TRIUMPH ANALYTICS AND ITS PRIVACY OFFICER You can reach TA, including our Privacy Officer, by writing:
Privacy Officer
Triumph Analytics
13600 Heritage Parkway, Suite 200
Fort Worth, TX 76177
or emailing: privacy@trilogyanalytics.media.
Last Updated June 12, 2024
TA offers a suite of digital marketing services designed to help online advertisers generate a higher return on their marketing investment. In the course of providing these services, we collect, use, and disclose data about consumers like you. Our online and digital services include: 1) Online (also known as cross context) Behavioral Advertising Services performed through TA’s data management platform and “demand side platform” (“DSP”) and, 2) Optimization and Analytics Services, and 3) Audience Management Services.
This ODS Privacy Policy describes our practices regarding collection, use, and sharing of data through our online and digital services and instructions for opting out of our use of data that relates to you for online behavioral advertising.
Understanding Online and Digital Services
The infrastructure of online advertising and dynamic websites is technologically complex. We want to be as transparent as we can be by explaining the range of things we do with data. We also don’t want to overwhelm you with technical details and want for our privacy policy to be understandable. We think we’ve struck the right balance, but if after reading this privacy policy you still have questions, you may contact privacy@triumphanalytics.ai for more information.
Our Consumer Mission
At TA, we want digital advertising to be a useful complement to your online experience. We want to deliver personalized, well-chosen ads to help you discover things that interest you—new websites, new products, new bargains. Our advertising business also helps fund the free content and services you enjoy across the Internet.
We use complex technology to pick the best ads to show, based on what we know about the context: the ad itself, the page that needs an ad, the time of day and other external factors, and information linked to your browser or mobile device digital advertising identifier.
If we can make ads more relevant for you, that makes advertising more valuable to advertisers, and websites make more money per ad, which pays for the websites, apps, online features and content that they provide to you for free. Our Optimization and Analytics services help websites adapt to your preferences with customized content and functionality. Fueling ad-supported free content and services is an endeavor that we are proud to be a part of, and we hope you’re equally happy with the results. But if you’re not, see the section below titled “Opting Out of Personalized Advertisements.”
How We Think of You
Before describing the kinds of data we collect, it’s important to understand how we think of you and other online consumers. In the context of ODA services, TA does not know you personally, and we do not need to in order to provide you with relevant advertising. We place an identifier within a cookie on your web browser or use an advertising ID generated by your mobile device. To us, you, and anyone else that uses that browser or mobile device, are just “surfer82” for example. Our cookies are called “rfihub,” “zeta,” “zync,” “disqus,” “boomtrain,” or “netmng,” and you can find them if you search for cookies in your browser settings.
So, when we talk about “you” in this ODA policy, we are referring to information that we have associated with one or more identifiers associated with a web browser that you might use, or with an advertising ID associated with your mobile device.
There are, however, exceptions to this general rule. We perform “cookie matching” between our different cookies and with third parties. This can mean, in some cases, that browser or device-linked data can be associated with other identifying data. In one service called “Intelligent Retargeting” we use a cookie to allow us to send follow up reminders, and other ads based on your previous visit to a website. This is an example of OBA or cross context behavioral advertising.
Information We Collect
We collect several types of information from and about you, as described in this section. Not all of the types of data collection described below necessarily apply to you—it depends on your browser and device settings and which online services or content you access.
Our services help advertisers customize, target and report on the advertisements we purchase on their behalf across third party websites and mobile applications. While purchasing these ads across third party websites and mobile apps, we collect information about some of the sites that you and others may visit, the mobile apps that you may use, the precise location of your mobile device such as the GPS coordinates (based on the consent you provided to the app), and the searches that you and others may conduct while online in order to serve advertisements that we believe are relevant to your interests. Where we can reasonably infer that a particular computer and mobile device belong to the same user or household, we may extend our advertising campaigns across those devices, serving advertising across multiple browsers or devices. We also work with third-party data companies that help us tailor ads. Both as we provide this service to clients and when we work with these partners, we share personal data, which constitutes cross context behavioral advertising.
When you visit one of our advertiser’s websites or mobile applications (“apps”), or the websites or apps where we display advertisements, we collect information about your activity on that site (such as the page viewed or the advertising that you clicked on) or the location of your device, in order to show you relevant advertising (e.g., for local events), control how many times you may see the same advertisement, in addition to providing advertisers aggregate metrics that help them pay publishers for displaying this advertising.
We collect information about your device, such as unique device identifier, browser type and language, and about your connectivity, such as the IP address, the server your computer is logged into, and the operating system information. We collect information such as the URLs you visit, the date, time, and duration of your visit to each page, and certain commercially relevant keywords pertaining to the searches you conduct (e.g. “shoes”). When we provide Optimization and Analytics Services to our customers, we also collect information about your activities on our customers’ websites.
To learn about the ads you might like or dislike, we may also ask you questions directly—for example, we may provide a survey via an online ad that asks about which ads, products, or brands you like or dislike.
We collect information about our partners’ interactions with you—for example, by placing pixels on an advertiser’s web page that let us know if you ultimately purchased an item after we ran an advertising campaign that showed you an offer for that item. We obtain data from other companies that also use cookie or device identifiers to share similar information that they have collected about you with us. For example, we may partner with other companies to learn the kinds of products you like to buy online.
As part of our Optimization and Analytics Services and our Audience Management Services, we may collect names, email addresses and postal addresses as part of an online lead generation campaign or an email marketing campaign on behalf of one of our clients. We don’t make independent use of that data when performing these services, but use it only as directed by our client. But, as described above, our Intelligent Retargeting service may match online data with an email or postal address from TA’s ID Graph (see our General Services Policy for more details about the ID Graph) for purposes of sending you digital ads, email, direct mail, or SMS advertisements. We store all the information we collect from or about you in a profile in our database.
How We Use Information
We use the information that we collect directly or receive from other companies to find patterns that help us select better ads to serve you at any given moment. For example, we might assume that an ad for golf-related items is attractive to people who have recently clicked ads related to golf, or we might determine that a coffee ad gets a better response in the morning. Our technology can test millions of possibilities and build models using huge amounts of data to predict responses to advertising.
We perform cookie matching between the different cookies that TA uses. By doing this we are able to stitch together all of the information that we have across the different parts of our company to create a fuller picture of a consumer.
We make inferences from the data we assemble from these different sources in order to show you advertisements for products or services that we think may interest you. We sort your device/browser into interest or purchase intent “segments” such as “Footwear > Sports & Fitness > Indoor Fitness”.
We also use the information we collect to measure effectiveness of ads on behalf of our advertisers and clients.
We may also predict whether different identifiers associated with different browsers and different devices, like a laptop, a phone or a tablet, may belong to one person or household, and then link the activity we see across those devices into a common profile. We call this a “device graph.” We believe this helps us serve you better advertisements, control how many times you may see the same ad and provide better service to our advertisers. We make these predictions based on the device and cookie identifiers and associated interest and intent information that we receive from our third-party partners, as described above.
As part of our Optimization services, we gather information about how you interact with different areas of a website and use this to customize website content for you in future visits, or even the same visit.
Information Sharing
We produce reports and analytics for our clients regarding the performance of their online advertising campaigns and regarding the characteristics of people that were responsive to the ads, but we do not share the online profiles of individuals that our technology generates for commercial purposes.
Our DSP uses data linked to browsers, cookies, and IP addresses to buy ad space on third party websites and place advertisements into those spaces.
On the other hand, we may share any information we hold when we believe that we are required to do so by law (including legal processes like subpoenas, warrants or court orders), or as we believe necessary to protect the health, safety, or legal rights of any person.
Finally, we may transfer information to a successor or assignee in connection with a corporate change in control such as a merger or acquisition or other transaction.
Opting Out of Personalized Advertisements
See above for opt-out links and information to help you manage cookie settings on your browser.
If you opt out of interest-based advertising, you will be opted out for all the identifiers or devices that we have associated with you at the time of the opt out request. We use a predictive process to associate identifiers and devices and do not know definitively all devices or browsers that you may use, so that process is not guaranteed to be error free. If you want to be completely thorough, we recommend that you use this opt out process for each device and browser you use.
TA’s DSP complies with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving personalized advertisements by DAA members via the DAA website here. TA also complies with the regulating principles of the DAA of Canada (DAAC) and the European DAA (EDAA).
TA’s DSP is integrated with the DAA’s AppChoices program, which allows consumers to download and manage their privacy preferences in a mobile environment. You may download DAA’s AppChoices mobile app on your iOS or Android device in order to exercise choice regarding the collection of application activity for interest-based advertising. Links to those applications are below:
What happens when I opt out?
An opt-out in any of the tools listed here will have the same effect, and you do not need to make an opt out selection using more than one method (we list them all to give you options for your convenience). If you opt out of interest-based advertising, you’ll still see ads from us online, but they may not be tailored to your interests. Note that we’ll still maintain some “opt out cookies” on your computer to note the fact that you’ve opted out. Each opt-out cookie is associated with a particular computer and browser. So, for example, if you get a new computer, install a new browser, or clear your cookies, you’ll need to opt-out again if you still do not want interest-based advertising.
Browser-Based “Do Not Track” Mechanisms
TA’s DSP does not currently process browser-based “Do Not Track” signals, largely because they are not currently supported by the most popular browsers that are used by the vast majority of users, however, if and when these DNT mechanisms come into widespread use, TA will support them to the extent required by applicable laws.
Industry Compliance
TA complies with the following self-regulatory programs:
Canadian users who wish to learn more about that program, or opt out directly from the DAAC’s web site, may visit this page for more information.
Our Policy Regarding Children’s Online Data
TA does not knowingly collect or solicit information from anyone under 16 years of age. Our services are directed to businesses – advertisers and their agencies – and are not directed to children under 16. If we learn that we have collected personal information of a child under 16 without parental consent, we will delete such information. If you believe that we might have any information from a child younger than 16, please contact us as set forth below.
Personal Data Relating to European Union Residents
TA contractors utilize the EU’s Standard Contractual Clauses as its basis for transferring EU data to the United States for processing.
In addition to the privacy rights mechanisms linked above, you can also direct any questions or complaints about the use or disclosure of your personal information to the TA Privacy office by email to: privacy@trilogyanalytics.media. TA will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal information within 45 days of receiving your complaint. Be advised however that it may take as long as 90 days depending on volume.
If you are unsatisfied with the resolution of your complaint, you may contact your local data protection authority here.
Contacting TA
If you have any questions, please contact privacy@trilogyanalytics.media or send mail to:
Privacy Officer
Triumph Analytics
13600 Heritage Parkway, Suite 200
Fort Worth, TX 76177
Changes to this Policy Statement
We reserve the right to amend this policy statement from time to time. The effective date of the current version will be posted at the top of this page.
