Index Exchange, Inc. (“Index Exchange”) believes in all Internet users’ rights to privacy. This Policy explains the information collection, use, and disclosure practices of Index Exchange. It applies to all information received by Index Exchange whether in electronic, paper or verbal format.
THE INDEX EXCHANGE BUSINESS
The Index Exchange Online Advertising Exchange (“Index Platform”) prides itself on providing an atmosphere that is non-disruptive to Internet users. Our proprietary ad personalizationmethodologies enable advertisers to effectively direct their campaigns to the audience(s) they are looking to reach without engaging in profiling practices. Services offered by Index Exchange include a Web-based advertising exchange marketplace that enables publishers, advertisers, and ad networks to efficiently market, buy and sell digital and mobile advertising and ad inventory.
Through its ad server, Index Exchange also acts as a service provider to enable its publishers, advertisers, ad networks and other clients to collect and use data for advertising purposes on their digital and mobile platforms across the Internet. Publishers may use our services to process consumer data, which they collect or source. Their data collection, use, and sharing practices may be governed by their own privacy policies and differ from those found in Index Exchange’s Privacy Policy. We encourage you to refer to the privacy policies of any websites you visit and apps you use, to learn about their privacy practices before disclosing any personal information to them.
INDUSTRY SELF–REGULATION
Index Exchange prides itself on conducting business in a transparent and open manner. In line with those values, we support efforts for self-regulation in the internet-based advertising industry.
NAI
Index Exchange is a member in good standing of the Network Advertising Initiative (NAI), a cooperative of online marketing and analytics companies committed to responsible data collection for digital advertising, building consumer awareness, and establishing responsible business and data management practices and standards. Index Exchange adheres to the NAI Code of Conduct in all its operations.
DAA
Index Exchange adheres to the standards and practices outlined by The Digital Advertising Alliance, a consortium of the leading national advertising and marketing trade associations, promoting a self-regulatory program for online interest-based advertising. More information on the program can be found here.
INFORMATION COLLECTION, USE, AND SHARING
In general, like most standard website servers, Index Exchange uses log files to track transactions. These log files include internet protocol (IP) addresses, browser types used, postal or zip codes, the internet service provider (ISP) utilised, referring/exit pages, platform type, date/time stamps, device IDs, and number of clicks among others. This information is then used to analyze trends, administer the site, and personalizeadvertisements to users accordingly. Index Exchange does not collect a website user’s Personally Identifiable Information (PII) as defined under United States federal law. However, in the course of and for purposes of conducting its business, Index Exchange may collect and process the following consumer information that is considered Personal Information (PI) under the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) or Personal Data under the European Union’s General Data Protection Regulation (GDPR):
(1) browser and device information received from publishers is shared with advertisers and agencies for responding to requests for advertisements, forecast advertising inventory and troubleshooting any operation issues related to the Index Platform;
(2) IP addresses, including both IPv4 and IPv6 are used to bid on advertising inventory;
(3) geo-location data is used to bid on advertising inventory;
(4) Precise Location Data (data obtained from a device about the physical location of the device) is used to bid on advertising inventory;
(5) GPS coordinates, where available;
(6) unique Index Exchange UserIDs, stored in browser cookies, are used for profiles on the ad server;
(7) mobile device identifiers are used to understand mobile traffic and are shared with advertisers and agencies to personalize the advertising experience;
(8) Pixel Data (data obtained through or in connection with the placement of any pixel mechanism) is used as part of the user matching process;
(9) people identifiers provided by Index Exchange’s partners are associated to audience segments, and shared with advertisers and agencies;
(10) data on whether a user viewed or clicked on an Ad is shared with advertisers and agencies.
Index Exchange’s internal processes treat personal data in accordance with regulatory requirements and applicable privacy laws to ensure that information is stored securely and used only for allowed and intended purposes.
Index Exchange may combine information that does not directly identify an individual with data collected from other sources to provide publishers, advertisers and ad networks with information to improve the relevance of advertising presented to users and determine whether to bid on ad inventory. In addition, although Index Exchange does not directly engage in Cross-App Advertising, our technology may collect and/or pass through Mobile Device IDs (the unique identifier assigned to a device by the manufacturer) or Advertising IDs (for iOS 6 and later), instead of cookies, to recognize you.
Do Not Track Signal
Index Exchange does not honor the ‘DNT’ browser signal. Instead, we utilize the cookie based opt-out mechanisms to allow users to opt-out of all advertising. For more information, please see the “Your Choices” section below.
Cross–Device Linking
Cross-Device Linking is the process of making assumptions that certain devices are related to each other, i.e. they belong to the same user/household. Index Exchange may engage in Cross Device Linking for personalized advertising, ad delivery, and reporting. If you would like to opt-out of having Cross-Device Linking used by Index Exchange on your devices, please see the “Your Choices” section below.
Cookies (HTTP Cookies and HTML5 Cookies or Local Storage)
An HTTP cookie is an object that stores a small amount of data on behalf of a browser on a given device. By saving information in a cookie, websites can remember preferences or recognize browsers from one visit to another or from one website to another. Index Exchange uses both session-only and persistent cookies. More specifically, Index Exchange uses certain cookies that last only for the duration of a user’s internet session and expire when that user closes his or her browser, as well as certain other cookies that are used to remember a user when he or she returns to a website and will last for longer.
HTML5 cookies, also known as HTML5 Web Storage, or local storage, is a technology that allows a website or application to store information locally on a user’s computer or mobile device. Index Exchange uses HTML5 cookies, or local storage, in connection with its platform and website to support publisher monetization objectives and speed up page load time.
Index Exchange ultimately uses these technologies (referred to as “cookies” going forward) to facilitate transactions between buyers and sellers of digital advertising inventory and, among other things, to enable its demand-side partners, publishers, data management platforms, and other third-party clients (collectively referred to as “Index Exchange clients/partners” moving forward) to effectively: (a) target advertisements to users of digital media properties, (b) evaluate and assess their advertisements and campaigns; and (c) view and enforce user opt-out choices. Index Exchange’s platform further uses cookies to associate information that does not directly identify an individual user with browsers and devices, so that Index Exchange’s platform and Index Exchange clients/partners can then use the information to select advertisements and campaigns for delivery via the Index Exchange platform. Index Exchange engages in cookie syncing, which is the matching of Index Exchange cookie IDs to Index Exchange clients’/partners’ cookie IDs.
Index Exchange collects and stores IDs from a variety of domains, including adsrvr.org and casalemedia.com. These IDs are stored in either Index Exchange’s domain (casalemedia.com) or the publisher’s first party domain.
PII, PI, and Personal Data of Index Exchange Clients
Registering to become a member of the Index Platform and use of the Index Exchange User Interface, either as an advertiser or a publisher, requires the submission of PI, PII or Personal Data to Index Exchange. This can include the full name, mailing and/or billing address, email address, company name, and website URL. Index Exchange uses this information to service its accounts and respond to inbound inquiries related to sales or technical support requests. Communications to business users are related to the Advertising Exchange. The Index Exchange User Interface also uses Google Analytics technology to monitor traffic on the UI. All such information submitted is held by Index Exchange in strict confidence and as prescribed by corresponding regulatory authorities.
Index Exchange does not engage in any form of distribution or sale of PII, PI or Personal Data to third parties for their own promotional use. Index Exchange does not sell, supply, or otherwise make user PII, PI or Personal Data available to any third party under any circumstances, unless ordered to do so by a court of competent jurisdiction.
Information Obtained from Third Parties
Index Exchange may obtain data from third party companies for the purpose of informing ad selection. This data may include Personal Data as defined under the GDPR. Advertisers who are clients of Index Exchange may collect PII and Personal Data on their own websites. These details are provided directly by the individual Internet user through online order forms, contests, etc. PII or Personal Data provided through an advertiser’s website is not visible to Index Exchange while being entered, nor provided to Index Exchange at any time in the future. This personal data collected by the advertiser is subject to the privacy policy of the individual advertiser involved.
YOUR PRIVACY CHOICES
Web Browser Option to Opt–Out
Some of the ads you see on the internet or in applications on your mobile device are tailored to your interests and based on your activity online or in the applications on your mobile device. This type of ad tailoring — sometimes called “interest-based” advertising — is enabled through various technologies, including browser cookies, mobile advertising identifiers as well as other non-cookie technologies. Tailored digital ads help support the free products, services and content you enjoy online. To help protect your privacy, Index Exchange (along with other NAI members) has voluntarily agreed to abide by high NAI standards including offering an opt-out mechanism.
Opting out of interest-based advertising means that you will no longer be shown ads that have been tailored to your interests. It does not mean you will no longer see advertising online. When you opt-out, an opt-out cookie will be stored in your web browser signaling your opt-out preference to NAI members including Index Exchange.
Please note that if your browser is configured to block third-party cookies, then the opt out cookie may not work. If you delete your browser cookies, you will need to opt out again. The opt-out will not apply to the specific browser in which you set it. The opt-out process must be repeated for each different browser.
CLICK HERE TO OPT-OUT
INDEX EXCHANGE INC. OFFERS INDIVIDUALS THE OPPORTUNITY TO CHOOSE WHETHER AN INDIVIDUAL’S PERSONAL DATA (OR SOMETIMES OTHERWISE REFERRED TO AS PERSONAL INFORMATION OR PERSONALLY IDENTIFIABLE INFORMATION) IS TO BE DISCLOSED TO A THIRD PARTY OR TO BE USED FOR A PURPOSE THAT IS MATERIALLY DIFFERENT FROM THE PURPOSE(S) FOR WHICH IT WAS ORIGINALLY COLLECTED OR FOR A PURPOSE THAT IS MATERIALLY DIFFERENT THAN ANY PURPOSE(S) SUBSEQUENTLY AUTHORIZED BY SUCH INDIVIDUAL.
IN THE EVENT THAT YOU WOULD LIKE TO EXERCISE YOUR CHOICE (I.E. OPT-OUT) TO SPECIFY THAT INDEX EXCHANGE INC. MAY NOT DISCLOSE YOUR COOKIE DATA TO A THIRD PARTY, PLEASE VISIT THE NAI’S OPT-OUT PAGE BY FOLLOWING THE LINK BELOW.
CLICK HERE TO OPT-OUT
IF INDEX EXCHANGE INC. USES YOUR PERSONAL DATA (AS SOMETIMES OTHERWISE REFERRED TO AS PERSONAL INFORMATION OR PERSONALLY IDENTIFIABLE INFORMATION) FOR A PURPOSE THAT IS MATERIALLY DIFFERENT FROM THE PURPOSE(S) FOR WHICH IT WAS ORIGINALLY COLLECTED OR SUBSEQUENTLY AUTHORIZED, INDEX EXCHANGE INC. WILL OFFER YOU THE OPPORTUNITY TO OPT OUT OF SUCH USES AND/OR DISCLOSURES.
DATA RETENTION
Index Exchange may retain data for as long as needed to provide services. We may retain data even after an account has been closed or is no longer engaged in business with Index Exchange if retention is reasonably necessary to comply with our legal obligations or meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Privacy Policy or our contractual obligations. We also retain personal data for as long as is necessary to provide support-related reporting and trend analysis which is thirteen (13) months. After 13 months, we de-personalize data by creating data sets that cannot be traced back to individuals. Personal data will be destroyed according to our data destruction process.
INFORMATION SECURITY
Index Exchange follows strict Information Security policies to protect personal data submitted to us, both during transmission and once we receive it. Although we take steps to secure your information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
In the unlikely event of a confirmed security breach, Index Exchange will investigate and contact impacted persons within 72 hours of the breach.
We reserve the right to disclose your personal data as required by law, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; when we believe that disclosure is necessary to protect or exercise our legal rights; or to defend against legal claims.
EUROPEAN UNION AND SWISS RESIDENTS
Index Exchange transfers data from the European Union and Switzerland to the United States in accordance with the EU-US and Swiss-US Privacy Shield Frameworks. More information on the Privacy Shield program set forth by the U.S. Department of Commerce can be found at https://www.privacyshield.gov/eu-us-framework.
Index Exchange is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission for any violations of the EU-US or Swiss-US Privacy Shield Framework. Index Exchange may be held responsible if third party controllers to whom it transfers personal information or third party agents it engages to process this data on its behalf, act in a manner inconsistent with the Privacy Shield Principles. Index Exchange is required to disclose personal information in response to lawful requests to meet national security or law enforcement requirements.
Access to and Deletion of Personal Data
Individuals residing in the European Union or Switzerland have the right to access any of their Personal Data retained by us. You also have the right to have the data corrected, amended or deleted where it is inaccurate or processed in violation of the Principles.
You can make a request to access or delete your Personal Data via Index Exchange’s User Access Request portal.
Data Protection Officer
If you have a complaint regarding the response to your request to access or delete information, please contact our Data Protection Officer:
Attn: Index Exchange Data Protection Officer
Legal Army, S.L.
B88103700
María de Molina, 60 4th
28006 Madrid (Spain)
Email: gdpr@legalarmy.net
Recourse Mechanisms
If you have any questions or complaints regarding Index Exchange’s compliance with the EU-US or Swiss-US Privacy Shield framework, please contact us. If we are unable to resolve your complaint, you may submit the matter to the ICDR-AAA, an independent dispute resolution body designated to addressing such complaints and providing appropriate recourse free of charge to you. You may also invoke, under specific conditions laid out by the EU-US and Swiss-US Privacy Shield, the right to binding arbitration to resolve your complaint.
CHANGES TO THIS PRIVACY POLICY
Index Exchange may find it necessary to update this Privacy Policy from time to time. Any changes will be posted at this site. Except as otherwise required by law, any modifications made to this Privacy Policy will not materially affect the privacy of data collected by Index Exchange prior to the effective date of the policy change.
CONTACT US
To inquire about privacy concerns, please contact Index Exchange by mail, as detailed below, or using our online form.
Attn: Privacy Team
Index Exchange
74 Wingold Avenue
Toronto, Ontario M6B1P5 Canada
Residents of the European Union can make a request to access or delete their Personal Data via Index Exchange’s User Access Request portal.
Index Exchange processes PII, PI and Personal Data in accordance with this Privacy Policy. In addition to Index Exchange being a controller, other controllers may exist depending on the use of your Personal Data. If you have questions regarding the collection and use of Personal Data, please contact our Privacy Team who will direct any inquiries to the proper controller as applicable.
Any user who has consented to the use of their Personal Data by Index Exchange in accordance with the uses disclosed in this Privacy Policy, has the right to withdraw their consent to such use. In order to withdraw your consent, please contact our Privacy Team.