Privacy Policy

Engagement Technology, LLC. (“Engagement Technology,” “we” or “us”) provides a number of marketing services, generally involving gathering and managing data and creating data models, in order to help marketers and marketing platforms send relevant, data-driven marketing communications.  This includes services to improve direct mail, email, and digital and social media ad campaigns, by targeting them to consumers’ interests, activities and demographics. We provide this privacy policy (the “Privacy Policy”) to make consumers and our own clients better aware of our practices regarding how we collect, use and share their information. Please note:  this Privacy Policy refers to how we collect and use information to provide services to our clients. We address each of those in separate Sections of this Privacy Policy.  

The Information We Collect and Receive

We receive information from various trusted companies and sources that collect and supply consumer data.  We may also obtain data through public sources, like census data and other public files. 

• This data includes what we refer to as Personally Identifiable Information (“PII”) and information tied to PII regarding persons’ demographics and interests, or purchase data.  When we refer to PII we mean first and last name, postal address, mobile advertising ID, telephone number or email address.

• We sometimes group data about consumers’ interests, demographics, or online and offline activities (including website visits) into aggregated “Audience Segments,” which may be connected to PII or to other unique identifiers (which we also explain below).

• We also use unique, individual identifiers (“UIDs”) that we, or our marketing partners, create that are derived from PII but have been de-identified, through various means.  These UIDs are often used in delivering online ads, for instance, and in deploying online “cookies.” We refer to these as “non-PII.” To learn more about “cookies” please go to Section 6 titled “Cookie Technology, Pixels and Mobile SDKs.”

• We may receive these UIDs along with other “non–PII” (e.g., pages viewed, browser type, time and date of visits) that is based on website visits or email opens.  This data may be used to improve the operation of these websites, improve visitors’ experience to the websites, to identify or remediate possible threats to the website’s security, and for other operational and management purposes, as well as for “retargeting” relevant offers to visitors based on web browsing activity.

• Engagement Technology may also collect or receive information about consumers’ visits to websites and information regarding advertising exposure (“web log data”). Web log data may include browser type, IP address, type of ad served, and date of ad delivery. This information is used to optimize ad campaigns and measure their effectiveness. Web log data may also be used to provide ads about goods and services that are most likely to be of interest to individuals.

Like many marketing platforms and other companies, we may combine, link or aggregate the various data we collect or obtain in order to provide our services.  We refer below to all of the information we receive, collect, or create as the “Information” (whether used in combination or alone).

How We Use the Information

Engagement Technology uses the Information to provide its services, including those described on this website.  That may include the following:

• Tailoring direct mail and email campaigns, display, mobile and social media marketing to recipients more likely to be interested in those campaigns;

• Measuring the effectiveness of any of the above campaigns, based on which ads are most likely to be opened or lead to purchases;

• Enhancing our clients’ proprietary databases with more information about their customers (or prospective customers);

• Creating aggregated Audience Segments (also referred to in Section 2) based on similar demographics and/or interests or preferences (e.g., theater-goers, sports fans, technology sector employees).  These Audience Segments may consist of our marketing partners’ first party data, as well as our own proprietary data;

• “Retargeting” consumers through direct mail, email, display, mobile and/or social media, such as by targeting ads to visitors of a client’s website. To do this, we or a marketing partners of ours may deploy and read unique identifiers (such as through online cookies) that enable the “retargeting” of consumers through other channels based on their web browsing experience, often by linking these identifiers to other personal information in order to direct tailored marketing experiences;

• Matching one form of PII or UID to another form of PII or UID to better recognize and communicate with an individual across different marketing channels – sometimes called "identity resolution;"

• Providing and supporting related data services, such as (but not limited to) information verification and data hygiene, record look-ups, anti-fraud, and other analytics and database tools.

Consumer Privacy and Your Ad Choices

You may learn more about companies that engage in various types of online targeted and retargeted advertising, some of whom we partner with, and also learn about how to opt out of receiving targeted emails from those companies, by visiting the DAA’s opt out page at http:// www.aboutads.info/choices/.  We also recommend visiting the opt-out pages offered by the Network Advertising Initiative.  These “opt out” mechanisms rely on cookies, so if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device to ensure that we withhold our Online Marketing Services on all of them.  Similarly, if you use a new device, change browsers or delete the all of your cookies, you need to repeat this opt-out function again.

How We Share Data with Third Parties

Engagement Technology may share the Information (including PII) with customers, marketing services and platforms, and service providers and vendors that we retain, in order to provide the services we have described above (or other services we may add).   In addition to our customers, we may share the Information with the following:

• Marketing Partners: We may share the Information, including PII and Audience Segments, with various marketing partners to help them and their own customers send more tailored targeted communications.  We may also do so for analytical purposes, to measure campaign performance, or inform future campaigns, or to handle, analyze, or segregate the PII and other data that we handle for customers.

• Corporate transfers: If Engagement Technology or its significant assets are acquired by or merged into another entity, the Information will be transferred to that entity.   Some Information may also be shared in the course of due diligence for any such event.

• As Required by Law or to Protect Any Party: Engagement Technology may disclose Information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas, warrants, or law enforcement and government agency requests provided to us; or (b) to protect or otherwise defend the rights, property or safety of Engagement Technology or any other party.

Cookie Technology, Pixels and Mobile SDKs

As also described above, we and our business and marketing partners use cookies and similar technologies to provide marketing services, such as to target or re-target online ad campaigns, or to measure those campaigns.  For instance, we or a partner may track a particular browser’s activities to determine if seeing an ad tends to make consumers’ more likely to visit a web page; or we and our marketing partners may target online or offline advertising to users who expressed interest in a product through online activities.  Thus, we and others may set and access cookies, pixel tags and similar technologies on your device. We and others may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies. Cookies are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device.  Our (or other companies’) servers send your device a cookie when you visit a website. We and other online marketing platforms may use cookies to, among other things, “remember” you when you visit a website or receive an email, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. We use cookies to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Pixel Tags. A pixel tag (also known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages or email messages. When you access these web pages or open an email, pixel tags generate a generic notice of the visit, including the type of device being used, and permit us to set or read our cookies. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given website visit or opening of an email message. For email messages, turning off the display of images will disable pixel tags.

Disabling Cookies. Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our services and other services may be difficult to use or become inoperable. In addition disabling cookies will not necessarily opt you out of interest-based marketing; we instead recommend the opt out methods described in Section 4 above.

Non-Cookie Technologies. In providing our services, we, our marketing partners, or our clients, may work with third-party companies that use techniques other than conventional HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with our services.These technologies may not respond to browser settings that block conventional cookies, particular if you are using a Safari browser. You may opt out of some of these technologies by visiting the NAI’s opt out page at http://www.networkadvertising.org; however, if your browser is set to immediately delete or refuse opt-out cookies, or if you use a Safari browser, you may not receive the benefit of this opt-out, or your opt out cookies may be immediately deleted.  

Security and Data Integrity

Engagement Technology takes steps to help ensure that the Information we use is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to PII. 

Changes to this Privacy Policy

From time to time, we may update this policy.  If you are interested in how we use Information to provide services, we recommend that you check back for any changes to this policy.

Do Not Track

Like most companies, we do not respond to “Do Not Track” signals sent by browsers:  the industry has not reached a consensus as to how to fairly and uniformly implement and interpret such signals.

Our Services Are Not Directed to Children Under 13

Engagement Technology’s services are not directed to nor intended for anyone under the age of 13.  Whether for itself or for its clients, TowerData will not knowingly collect or maintain personally identifiable information from or about anyone under 13.