PRIVACY POLICY

Privacy Policy for Direct2EXchange

This Privacy Code governs the collection, use and disclosure of your information in any form, whether written or electronic, by Direct2EXchange or the Direct2EXchange platform (D2EX). This Privacy Code explains what information may be collected from you and how it is used. It also explains how you can ask questions, make suggestions, and express concerns about our privacy practices. Please read this Privacy Code carefully, and check back periodically as we may update it from time to time.

Why Do We Collect and Use Information?

We collect and use information to make online advertising more relevant, effective and less annoying to the viewer.

For advertising purposes, non-personally identifiable information data may be used for the following:

  • Limiting the number of times a user sees a particular ad
  • Showing ads in a particular sequence
  • Customizing ads to a particular geographic region
  • Showing ads related to the content of the web page on which they are shown
  • Determining when users respond to ads
  • Showing a particular type of ad or offer
  • Showing a more relevant ad or offer
  • Showing interest based ads

What Types of Information Do We Collect and Use?

Direct2Exchange does not collect personally identifiable information (PII), which is subject to the Personal Information Protection and Electronic Documents Act (PIPEDA). Be aware that our websites may contain links to other websites that are maintained by third parties who are not required to comply with this Privacy Code and for which Direct2EXchange has no responsibility. Please review the privacy policies on any external websites to determine their information handling practices. We collect only anonymous, non-Personally Identifiable Information, such as browser type (e.g., Firefox or Internet Explorer); domain type (.com, .ca, .net etc); operating system (e.g., Macintosh or Windows); Internet provider (e.g., Rogers or Bell); Browser language (e.g., English or French); browser type (e.g. Java or Unix); Location (e.g., IP address and/or postal code) and whether you respond to an ad. Direct2EXchange also collects click stream data (e.g., pages or products viewed and or products purchased on a client website and websites visited on the Internet).

Direct2EXchange uses this non-Personally Identifiable Information to create data segments, and these data segments are generally based upon the websites that you visit. Direct2EXchange also obtains information from 3rd party data providers who collect and make available information such as behavioral, contextual, and demographic data. For example, if you visit a number of travel websites, you may be flagged as being interested in taking a vacation.

Direct2EXchange also uses this non-Personally Identifiable Information to facilitate retargeting at a campaign or advertiser level. Retargeting is the process of serving an ad from a particular advertiser to a user, based on the fact that the user has previously visited the advertiser’s website.

Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns

How do we collect information?

We use technology managed by our partners and vendors in the performance of our Services, which may include cookies, beacons and tags to collect non-Personally Identifiable Information.

Cookies

Cookies are small text files that web sites place in your browser when you visit them or see an ad. When you return to the site or view another ad, a site can access these cookie files. Sites can then determine how often you’ve visited a site or seen an ad. These cookies do not and cannot provide Direct2EXchange with any personally identifiable information about an Internet user.

Beacons and Tags Beacons and Tags

Beacons and tags enable online advertising companies to collect data and serve advertising on web sites by allowing communication between a web browser and an ad server. A beacon (or web beacon) is a small transparent image that is placed on a web page. A tag is a small piece of computer code that is run by the web browser.

User Choice

If you are concerned about cookies, you may adjust your computer’s web browser settings to refuse all cookies. However, by doing so, you may not be able to use certain features on the websites you visit particularly pages requiring registration or take full advantage of all the website offerings and interest-based advertising. You can remove cookies by following directions provided in your Internet browser’s “help” file.

You may also simply opt out of receiving interest based advertisements provided by Direct2EXchange and the collection of Non-PII in connection with the advertisements we manage on behalf of our clients.

  • To opt-out of interest based advertising by AppNexus Inc. a third party provider of services to Direct2EXchange, click here. When you opt-out, an opt-out cookie (from adnxs.com) will be stored in your web browser. The Platform will know the choice you have made when it sees your opt-out cookie, and will apply your choice. If you block or delete the opt-out cookie, the Platform will not see your choice.
  • To opt-out of interest based advertising by DoubleClick, a third party provider of services to Direct2EXchange, click here.

If you buy a new computer, upgrade or change web browsers or take any action, which results in the deletion of  opt-out cookies, you will need to perform this opt-out process again. In order for the opt-out to work, your browser must be set to accept third party cookies. Opting out does not necessarily delete or replace all cookies from the adnxs domain.

To learn more about interest-based advertising, and to access the opt-outs of other online advertising companies, visit the Network Advertising Initiative opt out page. Click here.

Who does Direct2EXchange disclose information to, and why?

Direct2Exchange may disclose your information under the following circumstances: Your information may be processed and stored outside of the province in which you reside and/or outside of Canada by us, an affiliate or a third party service provider for the purposes set out in this Privacy Code and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your information. Direct2Exchange uses third party service providers to provide certain services, including the collection and analysis of data described above, and to serve and host advertisements. Our service providers must maintain the confidentiality of the information they receive from or on behalf of Direct2EXchange, and may not use such information for any purposes other than to carry out the services they perform for Direct2EXchange.

We reserve the right to use and disclose your information without your consent where required or permitted by law, for example, if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law, in order to protect or defend our legal interests, or to comply with applicable laws and lawful governmental requests.

Finally, we may transfer Platform data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

How is the information stored and how long is it kept?

Direct2EXchange uses generally accepted industry security standards on the Platform.

Non-PII stored in the platform is retained in the Platform in non-aggregated form for up to 12 months. Aggregated data is used for reporting and analysis, and may be stored in the Platform for up to 2 additional years.

What is Excluded From This Privacy Code?

This Privacy Code does not impose restrictions on: business contact information, including the name, title, business address or telephone number of an employee of an organization; publicly available information, such as an individual’s name, telephone number and address when listed in a directory or made available through directory assistance; or information that is aggregated and not associated with a specific individual, including demographic information and statistics.

Children: If you are under the age of 18, be sure to obtain your parent or guardian’s permission before you send any information to us, or anyone else.

How To Address Your Privacy Concerns?

Contact Direct2EXchange with any questions or concerns you have about your privacy or this Privacy Code by sending an email to our privacy officer at privacy@d2ex.com or by calling 416-270-9989.

This Privacy Code was last updated on March 2012