Updated: March 8, 2019
Effective Date: May 18, 2017
Valassis Digital Corp. (Valassis Digital, we, us or our) provides digital advertising technology, data and services (our Services) that allow advertisers to more effectively target ads to end users on the websitesthey visit and the applications they use. Valassis Digital also provides mobile location analytics services through PathPoint and maintains websites, including valassisdigital.com (our Sites, which includes ourwebsite located at https://www.valassisdigital.com/ and mobile applications and platforms) that provide information about us and our Services.
- The information we collect on or through or Sites, in providing our Services, when you access or use our Sites, or otherwise interact with us and how that information is used, disclosed, shared, and processed;
- How information about you is collected, used and disclosed by Valassis Digital when you access our Sites, mobile applications that use our Services, interact with other websites that interact with us or otherwise interact with us.
- Your choices regarding the collection and processing of your Personal Information.
It does not cover the privacy practices of third parties that we do not own or control.
It is important to note that we may provide third party content or links to third-party websites or applications, or include features that allow you to connect your account with third parties, such as financial institutions or social media platforms like Facebook.
Anytime you leave our Sites or Services or interact with third-party features, you should also read the applicable third party’s privacy policies and terms of service to make sure you understand how they might collect and share information about you (approaches and philosophies can be different).
Collection of Information
Information We Collect Automatically through Our Services
In order to help advertisers provide ads that are relevant to your interests, we and our business partners and service providers automatically collect information about your browsers and devices when you (or others using your browsers or devices) access or use websites or mobile applications that incorporate our Services. We use various technologies to collect this information, including cookies, pixel tags, web beacons, server logs, HTML5 local storage, Flash local shared objects (LSOs), statistical identifiers, mobile advertising identifiers (such as IDFA and Android Advertising ID), software development kits (SDKs), server-to-server transfers, and non-cookie technologies. The information we and our business partners and service providers collect includes the following:
- Personal Information: This is information that can be used to identify you personally, such as your name, address, email address and phone number. When we combine information that is not Personal Information (like Non-Personal Information or Usage Data, which we explain below) with Personal Information, we treat it like Personal Information for as long as it is combined. Personal Information does not include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person or that does not otherwise identify you as a natural person.
- Non-Personal Information: This is information that, when used in isolation, is not able to identify a natural person.
- Browser and Device Information: We collect information about your browsers and devices, including your browser type, device type, IP address, user agent string, operating system, mobile carrier, and identifiers assigned to your browser or device, such as the advertising identifiers assigned by platform providers or statistical identifiers that allow us to recognize your device, which we infer from the other information that we collect about your device.
- Usage Data: We collect information about your web browsing and application usage, including the date and time your browser or device accesses websites and applications that incorporate our Services, the specific pages accessed, the names or types of mobile applications accessed, actions taken on the page, conversions or transactions, advertisements viewed, and advertisements clicked.
- Device Location Information: If permitted by your browser or device, and with your consent, we may collect your location information for the purposes of serving ads that may be more relevant to you or helping to understand how you responded to ads served to you. For more details, please see “Your Choices” below.
Because we also have a conversational ad feature on our Sites, you may also provide, and we may also collect chat and messaging transcripts, surveys, transcripts and records of your communication to use, via your participation in one of our promotions, when you submit a technical support request, when you apply for employment, or when you request information, news or other content.
In general, we collect Personal Information that you submit voluntarily through our Services. We also collect information you submit in the process of creating or editing your account and user profile on our Website, when you register for a sweepstakes or other promotion, request a free sample, contact us for help or information, sign up for newsletters, provide feedback or otherwise voluntarily supply your Personal Information to us (e.g., direct messaging). For example, our registration and login process requires you to provide us you’re your name, valid email address and password of your choice. When you personalize your profile and use the features of our Services, we will collect any information you voluntarily provide, and we may also request optional information to support your use of our Services, such as your birth year, gender and other demographic information. We collect information in the form of content that you submit during your use of our Services, such as photos, reviews, ratings and other information you choose to submit. We may also collect information about you and your friends who use our Services, for any social network you may have connected from, in order to provide you with a more personalized experience. For example, we may collect your user ID or profile information that you have permitted to be displayed through our Services to display you as a friend or in association with your profile and collections. If you purchase an item through our Services, you will need to submit your credit card or other payment information which we may collect and store, so that our service providers can process your payment for the item. When you sign up for our Services or engage in other activities that we make available through or via our Services, we will collect the information designated along with such activity, which may include your contact information such as your address and phone number. We will also collect transactional information based on your activity with or via our Services, such as information you provide to purchase or ship an item. If you choose to sign up to receive information about products or services that may be of interest to you, we will collect your email address and other related information. Additionally, we collect information that you voluntarily enter, including Personal Information, into any postings, comments, or forums within our online community. We may also collect location information from your mobile device that is relevant to the services that you access through your mobile device.
We may require you to submit additional personal information to authenticate yourself if we believe you are violating our policies, such as a utility bill to verify your address. If you do not wish to share such information with us, you will be unable to complete any further transactions via the Website and/or with or via our Services.
Information We Collect from Other Sources, Including By You
We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including our business partners, data providers, other advertising companies, and publicly available sources. For example, this information may include:
- In-Store Location Information: We and our business partners may utilize our PathPoint in-store hardware sensors to collect hashed device identifiers, such as MAC address, and track visitor traffic in retail stores. The information that Valassis Digital collects for the purpose of providing location analytics services through PathPoint is limited to what is necessary to provide the analytics services.
- Past Purchase Information: We may collect information on past purchases from third parties.
- Postal or Email Addresses and Related Information Provided by our Business Partners: Our business partners may provide us with their customer data (which could consist of postal or email addresses or purchasing data).
- Publicly-Available Information: We may collect publicly available information from data providers, such as census data related to cities, regions, or other geographic areas as well as related demographic, income and education information of those areas.
- Contents of Emails (including Email Address): If you send an email to us, we will collect your email address and the full content of your email, including attached files, and other information you provide. We may use and display your full name and email address when you send an email notification to a friend through our Services, Website or the social network from which you have connected to our Services or Website (such as in an invitation, or when sharing your content). Additionally, we use your email address to contact you on behalf of your friends (such as when someone sends you a personal message) or notifications from a social network or other website with whom you have registered to receive such notifications. We may use this email address to contact you, for things such as notifications of limited edition shop sales and other related information. You may indicate your preference to stop receiving further promotional communications as further detailed below.
- Some of the emails we send to you may include a click-through link. Before you arrive at the linkedwebsite,you pass through our servers. We track these ‘click-throughs’ to help us determine your interest inparticulartopics and measure the effectiveness of our customer communications. In addition to ‘click through’data, we mayalso collect, store and analyze other Usage Information (defined below) about the products andservices we offerour customers.
Information Collected Via Technology
We engage in remarketing to market our Site across the web. When a user visits our Sites, a cookie is placed on the user’s computer. Users with this cookie may be targeted across advertising networks to receive relevant advertisements. You may opt out of this, but opting out does not cover the privacy practices of any advertisers or ad servers.
An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. We, or our service providers, may track your IP Address when you access the Service to assist with ad targeting.
Use of Information
We use the information we collect through our Services to provide, maintain and improve our Services, including:
- Serving targeted advertisements: We use the information we collect to select and serve advertisements that we or our business partners think may be of interest to you. These advertisements may be served on the browser or device from which the information was collected, or on a different browser or device that we have linked to the browser or device from which the information was collected. We also use this information to manage the frequency and type of advertisements you see across your devices.
- Measuring the effectiveness of advertisements: We use the information we collect to measure and analyze trends, usage, and the effectiveness of our Services and the advertisements we and our business partners serve, including clicks and views of advertisements and any resulting purchases, as well as physical visits to retailers or other businesses.
- Creation of audience segments: We develop audience segments which consist of combinations of various data, including consumer location activity, purchase intent, and online and offline interests based in part on your online activity. We offer these audience segments for licensing by third party data providers and cloud marketing providers.
- Cross-device linking: We use the information we collect to establish connections among related web browsers and devices (such as smartphones, tablets, and computers) for targeted advertising, analytics, and reporting purposes. For example, we may match a user’s browsers or devices if they share similar attributes that support an inference that they are used by the same person or household. This means that information about website activities or application usage history on your current browser or device may be combined and used with information collected from your other browsers or devices. So, for example, if you browse for new cars on your tablet, you may see an advertisement for new cars on your smartphone.
- Customer Catalyst: Our business partners may provide us with their customer data (which could consist of postal or email addresses or purchasing data), and we match that customer data with the applicable digital households and then enrich each digital household profile with real-time interest and location activity.
- PathPoint: We and our business partners may utilize our PathPoint in-store hardware sensors to track visitor traffic in retail stores. We use this information to analyze customer movements, infer customer behavior and preferences, and improve in-store operations.
- Other Uses: We also use the information you provide to use to operate the Services, including:
- personalizing the types of information that you receive from us;
- assessing trends in your use of the Services or purchases of products or services;
- customizing, improving and developing content and functionality that helps us better serve your needs;
- facilitating communication between us and you;
- effectuating your opt-out of our direct mail campaigns;
- providing you with information that we think may interest you, such as company news and certain products, services, special deals and promotions;
- providing features like your free credit reports and scores;
- displaying third-party advertisements that may interest you based on your activity on the Website and/or Services;
- enforcing our agreements with you;
- developing aggregate, non-identifiable data that may be used for our business purposes;
- sending you important administrative information regarding you, the Website or the Services;
- delivering information requested by you, for example in response to technical support requests;
- to deliver marketing materials to you;
- for promotions you may enter into;
- when you submit a resume, CV or other information for consideration for employment;
- engage in conversational advertising with you via Google AdLingo; and
- preventing fraud and other prohibited or illegal activities.
We may collect and use certain non-sensitive health-related information in delivering advertisements. This includes utilization of similar to and including the following non-sensitive health-related data segments: Men’s Health and Wellness, Women’s Health and Wellness, General Health, Seniors’ Health and Wellness, and Common Ailments and Illnesses such as flu, allergies, and seasonal ailments.
Advertising Data Retention
Sharing of Information
- With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property or safety of Valassis Digital or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- Between and among Valassis Digital and any current or future parent, subsidiary and/or affiliated company;
- With your consent or at your direction;
For more information about Google’s use of data via our partnership with Google, please review How Google Uses Data when you use our partners’ sites or apps.
For more information about our Terms and Conditions for partnership with Google for use of its AdLingo functionality, please see Google’s Platforms Policies Help.
We may also share aggregated information, which cannot reasonably be used to identify you, with third parties. For example, we may share aggregated information with our business partners to help them optimize their services.
Additional Mobile Considerations
If you receive SMS messages from us, you may opt out by following the opt-out instructions that we provide.
If you receive SMS messages from one of our customers, you may opt out by following the opt-out instructions provided by the brand you are communicating with or by contacting the brand. You may also contact us at ValDigital-Privacy@valassis.com, and we can help put you in touch with the brand regarding your request.
Social media plug-ins
On certain pages of the Website we may implement so-called “social media” plug-ins, in particular Facebook’s “like” button, LinkedIn “comment” / “thumbs up”, and Twitter’s “comment” / “retweet” / “♡” buttons. When you visit a page that displays one or more of such buttons, your browser will establish a direct connection to the relevant social media server and load the button from there. At the same time the provider of the social media service will know that the relevant page on the Website has been visited.
We have no influence on the data that any such social media provider collects on the basis of the buttons. According to the available information, however, if you do not click on the respective buttons, none of your personal data will be collected and stored unless you have logged onto to your social media account. In that case, certain user data (including your IP address at the time) may be collected and linked to the account information already present at the social media service. If you wish to prevent this, please log out of your social media accounts before visiting our Website.
In addition, clicking a button may also lead to a collection of certain data, such as your IP address. Social media providers such as Facebook, Instagram, YouTube, or Twitter may set cookies as well, unless you have disabled the acceptance and storage of cookies in your browser settings (see above).
We receive no information from social media providers about which social media buttons you may personally have clicked or seen on our Website. If at all, we may receive a summarized, non-personalized statistical report on the use of the buttons.
- LinkedIn Privacy: https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy
You may opt out of our use of information about your web browsing or mobile application usage for interest-based advertising purposes (including through the use of non-cookie technologies such as statistical IDs). Because we use different technologies to collect information across web browsers and mobile applications, we provide different choices for each environment. You can follow the instructions below to opt out in web browsers or in mobile applications, or to change your location settings. Please note that the opt-out will apply to the specific browser or device from which you opt out, and therefore you will need to opt out separately for each device and each web browser that you use and wish to be opted out on.
When you opt out of interest-based advertising in web browsers and mobile applications, as described below, we will no longer serve ads that are targeted based on your web browsing activity or application usage history to the browser or mobile device from which you have opted out (including through the use of non-cookie technologies such as statistical IDs). In addition, we will not use information collected from the browser or device from which you have opted out to serve you targeted ads on other browsers or devices that we have linked to that browser or device. Similarly, we will not use information collected from other, linked browsers or devices to serve you ads on the browser or device from which you have opted out. Please note, however, that we may continue to serve you ads that are not based on your web browsing or mobile application usage.
Opting Out in Web Browsers
Valassis Digital adheres to the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles. You can visit the DAA’s website to learn more about online advertising, and to opt out of having certain information used for interest-based advertising purposes on web browsers. European users can visit http://www.youronlinechoices.com/ to learn how to opt out of having certain data used for online behavioral advertising by European Interactive Digital Advertising Alliance (EDAA) member companies such as Valassis Digital. To opt out solely from Valassis Digital’s use of information about your web browsing activity for interest-based advertising purposes (including through the use of non-cookie technologies such as statistical IDs), please click here: Ad Cookie Opt Out.
When you opt out using any of these methods, we will place an opt-out cookie on your browser. This cookie is only effective as to the device and browser where the opt out is made. If you want to opt out for multiple browsers or devices, you must opt out on each browser and device individually. You may need to enable cookies in order to opt out using any of these methods, and if you delete your cookies, you may need to renew your opt-out choice. You can download the DAA’s Protect My Choices browser extension to help preserve your opt-out preferences.
Please note that when you delete or clear cookies from your browser, you will not necessarily delete the Flash Local Shared Objects stored on your computer. You can review Adobe’s Website Storage Settings panel to view, delete, and control Flash Local Shared Objects.
Opting Out in Mobile Applications
- Your mobile device may provide you with a setting that allows you to opt out of having your data used for certain advertising activities (Limit Ad Tracking on iOS, and Opt out of Interest-Based Ads on Android). Valassis Digital treats these signals as an opt-out for that particular device and will not use information collected in mobile applications on that device for interest-based advertising purposes (including through the use of non-cookie technologies such as statistical IDs). To adjust settings on your mobile device, please visit:iOS: Settings > Privacy > Advertising > Limit Ad Tracking
- Android: Settings > Google > Ads > Opt out of interest-based ads
We also participate in the DAA’s Appchoices opt-out program, which you can learn more about at http://youradchoices.com/appchoices.
Effect of Opting Out
When you opt out using any of these methods, we will no longer serve ads that are targeted based on your web browsing activity or application usage to the browser or mobile device that has opted out, regardless of where such information was initially collected, and we will not use information collected from the device that has opted out to serve you targeted ads on other browsers or mobile devices. We may continue to serve you non-targeted ads.
Opting-Out for Device Location Data
When you first download or open any applications that incorporate our Services, you may be asked to consent to the collection of location information from your device. If you consent to the collection of this information but later wish to withdraw your consent, you may do so at any time by either changing the settings on your mobile device or deleting the mobile application.
Mobile Location Analytics Opt Out
Valassis Digital complies with the Mobile Location Analytics Code of Conduct. As provided for in the code, you may elect to opt out of associating information about your presence at a location with a device’s MAC Address at: https://smart-places.org/. If you opt out, we will use your device’s MAC Address only to maintain the device’s opt-out status.
Do Not Track Requests
Valassis Digital does not honor Do Not Track (DNT) requests at this time.
Information Collected on Our Websites
Prospective customers may provide contact information through our Sites to find out more about Valassis Digital and to be contacted by a Valassis Digital representative. Valassis Digital (and its agents and service providers) may use this information to respond to your request, to send you marketing communications, and for business purposes such as marketing and research. We will not rent or sell this information to other companies. You may opt out of receiving promotional emails from Valassis Digital by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. Valassis Digital will use any other information submitted on our Sites for the purpose for which it was collected, including to respond to your inquiry.
The Sites are not intended for use by children under the age of 13. Valassis Digital does not knowingly collect or use any personally identifiable information from children under the age of 13, and does not use any information collected from websites or mobile applications directed to children for interest-based advertising purposes. If we learn that we have collected the personally identifiable information from any such children, we will take steps to delete the information as soon as possible.
Notice to Residents of Countries Outside the United States
California Privacy Rights
Pursuant to Section 1798.83-.84 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, what types of personal information, if any, the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, please contact us by emailing ValDigital-Privacy@valassis.com with CA Privacy Requests in the subject line. Please note that, under the law, we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any requests that are not sent to the above-designated email.
Regarding Residents of the European Union & GDPR
We seek to comply with all applicable privacy laws and regulations that apply to residents of the EU. Residents of the European Union (“EU”) may only use our Services after providing us your freely given, informed consent for us to collect, transfer, store, and share your Personal Data, as that term is defined in the EU’s General Data Protection Regulation (“GDPR”) or to the extent we have a legitimate basis to collect, transfer, store, and share your Personal Data.
Valassis Digital uses commercially reasonable technical, administrative, and physical safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your information.
International Data Transfers
If you are located outside of the United States, please note that we may transfer your personal data outside your country of origin. By providing or making available your personal data, you consent to that transfer.
How to Contact Us