Confirm Your Privacy Notice Addresses NextRoll’s Technology
NextRoll's Technology (i.e., the pixel) collects data. You are required to post an accurate privacy notice with appropriate disclosures and information for your website visitors within 30 days of adding the pixel.
Why You Need a Privacy Notice
To help you learn more about who might be interested in your brand and fuel the growth of your brand, the pixel collects data about visitors to your site.
Generally speaking, you have a legal obligation to disclose information about the types of data collected from visitors to your site(s), the third parties with whom that data is shared, and how visitors can control that data collection.
What do we mean by “generally” here? Well, because there is not one comprehensive global privacy law, the specific details of what your policy notice must contain will likely vary depending on where visitors to your site reside—for example, whether your site has traffic from visitors in the U.S. or Europe—and the types of NextRoll services you use.
We’re here to help make sure your site discloses the necessary data collection and control information implicated by your use of the pixel in specific jurisdictions. In other words, there may be privacy compliance measures you need to take based on the type of business you operate and where your business operates. It is important to note that this article only identifies the information required to be in your privacy notice resulting from the use of the pixel (see below).
Privacy Notice Disclosures
WHAT MUST BE IN YOUR PRIVACY NOTICE
When using the pixel for any of our services, you must notify the visitors to your site of the use of our services by disclosing the following information in your Privacy Notice
|What and How Personal Data is collected||
You must disclose that personal data, such as visitor IP addresses, is collected from visitors to your site using tracking technologies such as third party cookies and non-cookie technologies.
Hot tip: When we say “Personal Data” we mean this to include “personal information” (often referred to as “PI”) and/or “personally identifiable information” (sometimes called “PII”) as defined or described in different privacy laws around the world (and in the U.S.).
|Purposes for Which the Data is Used and by Whom||
|How Visitors Can Control the Collection of their Data by NextRoll||
Include instructions for visitors to control the collection of data by web browsers and mobile devices.
Example: Let your visitors know they can decline to have personal data collected via third party tracking technologies by navigating to the settings feature in their browser and declining all third party cookies or declining third party cookies from specific sites, or, for mobile, limiting ad tracking or resetting the advertiser identifier via the privacy settings on their mobile device.Provide an opt-out link or third-party tool that opts users out of targeted or interest based advertising. Available third-party opt-out tools include: the Digital Advertising Alliance, the Network Advertising Initiative, and the European Interactive Digital Advertising Alliance (Europe only). See RollWorks’ opt-out article for an example.
|ADDITIONAL DISCLOSURES REQUIRED IN YOUR PRIVACY NOTICE DEPENDING ON WHAT ROLLWORKS SERVICES YOU ARE USING|
|You are using Cross-Device||
Example web form disclosure:
Your information is being used for our own marketing purposes. Our advertising Partner, NextRoll, Inc., performs a hash of your email address in order to serve targeted advertising to other devices connected to you (via cross-device tracking). By submitting this form, you acknowledge NextRoll, Inc.’s hashing and cross-device activity. For more information, please see NextRoll’s Privacy Notice.
|You are using Sales Insights||
In the section of your Privacy Notice for “Purposes For Which Data is Collected” make sure you disclose that you collect emails for direct marketing purposes in addition to your other purposes (if any).
|You have website visitors from California, USA||
A link to the California Residents section of NextRoll’s Service Privacy Notice.Hot tip: For more information about this disclosure, please see this article.
|You have website visitors from Europe||
If your site attracts visitors from European Territories (European Territories includes the European Economic Area, Switzerland, and the United Kingdom), the General Data Protection Regulation (“GDPR”) applies to your business and you are a GDPR-impacted customer. In addition to using a “consent mechanism” to obtain consent to collect personal data via the pixel, the GDPR requires that you include at least the following information in your privacy notice:
Hot tip: NextRoll also provides Customers the option to use NextRoll’s consent banner. For more information, please click here.More information: Please remember that the required disclosures described above relate to the use of the pixel and should not be construed as legal advice for the operation of your specific business. Privacy laws vary across different countries and territories and may apply to the operation of specific industries. Only your business can determine all the disclosures, language, and requirements that must be included in your privacy notice to account for all the unique aspects of your business.
Where to Place Your Privacy Notice
You should have a clearly visible link to the privacy notice on all site pages where personal data is collected and the pixel is placed. The privacy notice link must be clearly and conspicuously placed on the home page and should be easily accessible within a few clicks of the landing page.
Privacy Notice Disclosure Examples
Set out below are examples of the type of information you need to include in your privacy notice. We provide these examples to inspire you while drafting or updating your privacy notice: you are not required to use the exact language below. The disclosures will vary depending on (a) what NextRoll Services you are using and (b) what jurisdictions your business operates in.
Collection of Data
Our site uses technologies of third-party partners [such as NextRoll] to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, [NextRoll/these partners] collect information about your activity on our site(s) to enable us to:
- measure and analyze traffic and browsing activity on our site(s);
- [Optional: if you are using our Media Services to run campaigns, include this disclosure] show advertisements for our products and/or services to you on third-party sites;
Cross-Device [Optional: if you are using our Cross Device Services] We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with [NextRoll/ our advertising partners]. This allows our partners to recognize and deliver your ads across devices and browsers. To read more about the technologies used by [NextRoll/our partner] and their cross device capabilities please refer to NextRoll’s Privacy Notice.
Our partners [such as NextRoll] may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising
- The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA’s opt-out platform: http://www.youronlinechoices.com/
The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN