Privacy Notice Requirements for Retargeting and Prospecting Ads

In order to successfully run ad campaigns, Springbot automatically places a pixel from our partner, NextRoll, on your site (the “NextRoll Pixel”). After the NextRoll Pixel is added during the NextRoll integration, NextRoll will review your privacy notice to make sure you have all of the required information. You are required to post your privacy notice within 30-days of the NextRoll Pixel being added to your site.

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, NextRoll’s 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 is meant 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 services you use.

This document’s purpose is to help make sure your site discloses the necessary data collection and control information implicated by your use of the NextRoll 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 NextRoll Pixel (see below).  NextRoll has told us that it may prevent users without appropriate privacy notices from running ad campaigns, which could negatively impact your business.

Required Information 

When using the NextRoll Pixel, you must notify the visitors to your site of the use of retargeting and/or prospecting services by disclosing the following information in your privacy notice:

  • What Personal Data is Collected and How
    • 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.).
    • 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.

  • The Purposes for Which the Data is Used and by Whom
    • You must disclose:
      • The third parties with whom personal data collected on your site is shared; and 
      • why this data is collected (i.e., the purpose for collecting personal data). 
      • For example, you can disclose that third parties (such as NextRoll) may place cookies on the browser used by the visitor in order to serve targeted advertising and for measurement and analytics purposes.

  • How Visitors Can Control the Collection of their Data by NextRoll including:
    • You must include instructions for visitors to control the collection of data by web browsers and mobile devices. For 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; AND
    • You must 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 AdRoll's opt-out article for an example).

If Your Site Attracts Visitors from California

If your site(s) receive visitors from California, you must include the following information in your privacy notice: 

If Your Site Attracts 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 NextRoll’s Pixel, the GDPR requires that you include at least the following information in your privacy notice:

  • Disclosure of the purposes of processing the personal data collected on your sites 
  • The legal basis you rely on to process each type of personal data (e.g. consent); and
  • Identification of the entities that receive (or with whom you share) the personal data collected (i.e. Springbot, Inc.). 

NextRoll also provides Customers the option to use NextRoll’s consent banner. For more information, please click here.

Please remember that the required disclosures described above relate solely to the use of NextRoll’s Pixel and should not be construed as legal advice for the operation of your specific business or for any other purpose. Privacy laws vary across different countries and territories and may apply to the operation of specific industries. Only your business and your counsel 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. 

Privacy Policy Example 

If you have an existing privacy policy but your campaign is still rejected by NextRoll, you may need to update your privacy policy. Below are examples of the type of information you need to include in your privacy notice. The disclosures will vary depending on (a) what services you are using and (b) what jurisdictions your business operates in.  As noted above, this is an example and should be appropriately tailored for your business. Once this is complete, please reach to help@springbot.com so we can relaunch your campaign! 

Privacy Policy Example:

Information Collection, Use, and Sharing:
At (ENTER COMPANY NAME)l, we have a huge respect for your privacy. Third parties (such as AdRoll) may place cookies on your browser for targeted advertising, analytical and/or measurement purposes. Information collected may include IP addresses, cookie identifiers, website activity and non-tracking technologies

Collection of Data:
Our site uses technologies of  third-party 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, 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);
  • show advertisements for our products and/or services to you on third-party sites;
  • measure and analyze the performance of our advertising campaigns; 

Opting-Out 
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 opt out here to decline the collection and use of information for the purpose of serving you interest based advertising.

Here are other ways in which to control your data:

  1. Web Browser: You can opt-out of receiving interest-based ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided.
  2. Cross Device Opt- Out: In some cases, we may link multiple browsers or devices to you. If you opt-out on a browser or device and we have additional devices or browsers linked to you, we will extend your opt-out decision to any other linked browsers and devices. Since we only link users across browsers and devices in certain conditions, there may be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
  3. Mobile Device Opt-Out:To opt-out of receiving interest-based ads that are based on your behavior across different mobile applications, please follow instructions for iOS and Android devices:
    1. iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
    2. For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Select Ads > Enable “Opt out of interest-based advertising”.

California Residents
For California residents, please refer to California Residents section of NextRoll’s Service Privacy Notice. For more information about this disclosure, please see this article.

European Residents
For European residents, (ENTER COMPANY NAME) uses NextRoll services to provide Retargeting and/or Prospecting ads to current and potential customers. Any personal data collected may be shared with NextRoll to facilitate these services.

 

Content Guidelines 

NextRoll has guidelines as far as the content that is included in ads as well as the content with the website associated with the ad. Below are some common topics prohibited by NextRoll; please note that these restrictions apply to the ads in a campaign as well as the website: 

  • Adult Content-Including imagery / website content that displays nudity, graphic language or other adult concepts. 
  • Alcohol - Including imagery / website content that displays alcohol or the consumption of alcohol.
  • Shock Value - Including imagery / website content that is designed to disturb, scare or shock.
  • Spam Tactics- Including imagery / website content that mimics computer functionality such as a progress bar, prompt to download a file.
  • Violence and / or Weapons
  • Body Images / Health or Fitness- Including imagery / website content that displays "before and after" weight loss pictures, sets unrealistic expectations or draws unnecessary attention to specific body parts.

Please note NextRoll also requires that all ads display the advertiser's brand so that site visitors have a clear understanding of where they will be going if they do click on the ad. The brand on the ad must also match the destination of the landing page. Typically as long as an advertiser's logo is included on the ads, the campaign will be approved by AdRoll.


Questions? Our team is here for you! If you need additional help, please drop us a line at help@springbot.com.