1. Our Commitment to Data Privacy
The security of personal information relating to our clients and other end users is treated as a matter of critical importance within Conducive Search.
Conducive Search follows industry best practices for stewardship of data, including transparency, accountability and choice regarding the collection, use, and disclosure of information. Conducive Search is committed to protecting the data from any users of our services and our partners and maintaining compliance with all applicable laws, including the EU’s General Data Protection Regulation ("GDPR").
As our company, technology and services evolve, this Privacy Notice may be revised to reflect those changes. Notice of such amendments will be posted as an updated Privacy Notice on this website. Please review this Privacy Notice periodically in order to keep up to date with any modifications.
2. Who is Conducive Search?
The entity that decides how and for what purpose data is processed (also referred to as a "data controller") is:
Conducive Search. d.b.a adMarketplace, Inc.
1385 Broadway, 19th Floor
New York, NY 10018
Tel. +1 212 925 2022
Email: firstname.lastname@example.org; email@example.com
3. Purposes of and Legal Bases for Data Processing
Conducive Search uses personal data relating to identifiable individuals ("personal data") as set out below:
- If you are an internet user visiting one of our websites: We process personal data in order to deliver the most relevant ads to you. Our hosted properties have a search box where you can enter search queries and our technology platform shows ads in the following ways:
- Conducive Search
- Before your search ("pre-search"): we show tiles for different trusted brands with which we have commercial relationships ("Our Brands") below our search box using data signals to predict those that may be of most interest to you;
- During your search: we show relevant, "instant search" links for Our Brands based on what you are typing and these links allow you to directly navigate to the brand site and "skip" the search-engine results page (the "SERP");
- Search Results ("post-search"): you’ll see your search results and we add related sponsored links from Our Brands;
- Omnibox Search: we will auto-complete and/or redirect your mistypes and misspells, by bypassing parked pages, to Our Brands’ domains that you had the intention to type
- We ensure ads comply with applicable regulations and our obligations, to provide our customers with reports to analyze their campaigns (such as which ads were delivered and the number of clicks), and to detect and prevent fraud.
Using IP addresses helps us ensure ads are running in permitted territories, to better place ads, and flag fraudulent traffic. Cookies may be used to track how you interact with the advertisement (please see section 10 below).
Our legal basis for this processing is:
- For display of advertising: your consent (which you give to Conducive Search when you visit a Conducive Search site); and
- For analytics and fraud prevention: that data processing is necessary for our legitimate interests and those of our clients, namely improving our products and services, charging correctly for our services, and reducing fraud.
- If you are a visitor to our website: our legal basis for processing your personal data is:
- When you contact us with inquiries, complaints or request other assistance: your consent; and
- For technical data relating to your device/network: that data processing is necessary for our legitimate interests, namely improving our website and products and services.
- If you work for a customer or supplier (or potential customer or supplier):
- Where we provide products or services to you or purchase products or services from you: That it is necessary for the performance of our contracts with our customers or suppliers;
- Where you are an authorized user of our online customer portal: in order to provide access to materials and product features, this being necessary for performing our contract with you or for our legitimate interests in managing our relationship with you;
- Where we send newsletters or other commercial offers: that it is necessary for our legitimate interests in managing and developing our business;
- Where we keep data for legal, recordkeeping, tax or accounting purposes: that it is necessary to enable us to comply with the legal obligations that apply to our business.
- This Privacy Notice does not apply to personal data processing that relates to our employees or other staff, or to applicants for positions with any of our group of companies, as these activities are governed by separate privacy notices. Please contact our Legal and HR department for more information at firstname.lastname@example.org.
4. What Personal Data do we Collect?
- Search information
Conducive Search’s network shows ads to visitors of our websites. We receive and analyze the search terms (keywords) entered into the search box on those sites. We may also receive technical information such as your approximate location, browser type, language settings, user agent, timestamp, cookie ID and IP addresses. We also receive information regarding which ads were viewed or clicked on and that you arrived on or made a purchase from one of our advertiser’s websites.
When a user types a search query, we will match ads between the current user agent and IP address and the search query, and those ads will appear in the scroll down menu below the search box. If the user clicks on the ad, we will collect the click information (along with ad information…), then a cookie will be dropped on the user’s device. If the user proceeds to the site redirected from the ad he clicked on, and if the user then purchases a product or a service or completes an action during that session, then a conversion pixel might be fired from the advertiser site. This helps Conducive Search and the advertiser measure the effectiveness of its advertising.
When the user uses our products in a mobile environment, we might sometimes collect the device IDs (unique identifiers to the phone the user is using).
On our "contact us" links, an email address (email@example.com) is provided so that you can input your name and contact details. We collect this information so that we can respond to the comments or questions that you send us. If you do not provide us with this information we may not be able to fully complete your request. We do not merge any such information collected via our email contacts with other data collected on our website.
In order to maintain and manage our website, we record other information such as IP addresses, page views and clicks, and cookies for gathering website statistics. We also store IP addresses on our server in the event that our site becomes corrupted and it becomes necessary to discover the cause.
- Business Contacts
We collect billing and contact information in order to administer our customers’ accounts, and fulfill the services they request, and also when we are evaluating or purchasing goods and services from new or existing vendors.
In order to provide certain services, we may also collect information from you when you attend one of our events, during phone calls with sales representatives, or when you contact a Conducive Search representative. We may on occasion supplement the information you submitted to us with information from third party sources to verify your address as part of our anti-fraud effort.
We may also obtain information from public sources, such as professional networking platforms, trade shows, or other directories, as part of our business development activities.
- Conducive Search applies commercially reasonable security measures to protect data from unauthorized access, corruption or loss. These include storing information in databases which are protected by security measures such as password protection and encryption at rest using Transport Layer Security technology (TLS), so that even if the data is improperly accessed, it is less likely to be in an intelligible format. When no longer required, this data is moved to our secure archive server, also encrypted and password protected and only accessed for regulatory, legal or business reasons.
6. Third Parties
- We may provide data for specific purposes to data processors (e.g. for storage, analytics, or fraud detection), especially our publisher partners, agencies and advertisers. Our contracts for these services comply with the Privacy Shield Principles for onward data transfers, including obligations to provide the same level of protection.
- We may also disclose your personal information, where we believe this to be necessary or appropriate: (a) under applicable local, national, or international laws; (b) to comply with legal processes; (c) to respond to requests from any public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- Although this website contains links to other websites, please be aware that we do not endorse and are not responsible for the privacy practices of those, or any other sites. If you follow a link to another website you should carefully read their privacy notice and terms and conditions.
- Although this website contains links to other websites, please be aware that we do not endorse and are not responsible for the privacy practices of those, or any other sites. If you follow a link to another website you should carefully read their privacy notice and terms and conditions. Publishers, agencies or advertisers with whom we work may use additional cookies, web beacons and other technology to collect information about you, including for advertising purposes. Conducive Search does not control publishers’ or advertisers’ use of such technology. To learn about how a particular publisher may use your information, you should read their privacy notices and terms and conditions.
7. International Data Transfers
- Conducive Search stores and process data in the USA. Conducive Search complies with the requirements of the EU-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from customers in the European Union and EEA member countries. Data from the UK is specifically included for such proposes. For the purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. Conducive Search has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability
- Conducive Search does not knowingly or specifically collect information about children under the age of 13. If you believe that we have mistakenly or unintentionally collected such information, please notify us at firstname.lastname@example.org.
9. Retention of Data
- For internet users to whom we show ads, we keep this for up to thirteen (13) months for advertising purposes. Aggregated and anonymized or statistical data may be retained for a longer period for reporting to and billing our customers.
For website visitors we may retain data for as long as it takes to answer your queries. We may also continue to use data in aggregated and anonymized form to analyze and improve our website and products.
For business contacts, data will normally be kept for the duration of any contractual relationship and for six years after it ends (in order to be in a position to address any legal claims that could be made). We may need to keep data for longer for legal compliance, accounting, tax or recordkeeping purposes, in which case it will be kept and used only for such purposes
If we don’t have a contractual relationship then we will regularly review the data and delete it when no longer necessary for the original purpose, but we will retain it for as long as we are in contact (e.g. if you have subscribed to a newsletter or other publications from us, or we are evaluating a business relationship).
- A cookie is a small piece of data sent from a website and stored in a user’s web browser. When the user loads a website that is set up to react to that cookie, the browser sends cookie information to the server and the website that it recognizes the user.
You can find more information about different types of cookies at allaboutcookies.org.
For opting out from mobile devices please review your privacy control settings. For more information visit:www.networkadvertising.org/mobile-choice
11. GDPR Rights
- If you are in the EEA, including in the EU or the UK, you have various rights in relation to your personal data which may include the rights:
- to request access to it
- to request rectification of incorrect data
- to ask for it to be erased (the "right to be forgotten")
- to object to its processing
- to ask for a copy to take to another service provider ("data portability").
- If our data processing is based on your consent, then you can always withdraw that consent (but any processing that took place before withdrawal will still be legal).
If you request that data should be erased, the usual method for this is to remove all personally identifying elements so that the data is permanently anonymized and cannot be traced back to you.
In case of any issue, please contact us using the details in this Notice and we will help as far as we can. If you believe that we have not respected your rights then you also have a right to make a complaint to the Supervisory Authority in your country (e.g. in the UK, the Information Commissioner’s Office: ico.org.uk ).
You may ask to exercise any of your rights by submitting a request to: email@example.com.
12. EU-U.S. Privacy Shield
- To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.
- Any questions or complaints concerning our Privacy Shield compliance may be directed to firstname.lastname@example.org. If we have not been able to satisfactorily resolve the issue, then, you may submit your complaint to JAMS using this link: www.jamsadr.com/eu-us-privacy-shield, adMarketplace’s designated Privacy Shield dispute resolution provider. Under certain conditions specified by the applicable Privacy Shield Principles, you may also be able to invoke binding arbitration to resolve your complaint.
Your rights under the CCPA:
Your rights under the CCPA can broadly be divided into the following categories: (1) right to notice, (2) right to access, (3) right to opt out (or right to opt in), (4) right to request deletion, and (5) right to equal services and prices.
Right to notice: Under the CCPA, businesses must inform consumers at or before the point of collection what categories of personal information will be collected and the purposes for which these categories will be used.
Right to access: Consumers have the right to request that a business disclose the categories of personal information collected; the categories of sources from which personal information is collected; the business or commercial purpose; the categories of third parties with which the business shares personal information; and the specific pieces of personal information the business holds about a consumer. If a business sells personal information or discloses it for business purposes, consumers have the right to request the categories of information so sold or disclosed.
Right to opt-out: Consumers have the right—at any time—to direct businesses that sell personal information about the consumer to third parties to stop this sale, known as the right to opt-out. If a consumer is a minor, the CCPA provides for a right to opt-in to the sale of data (exercised by the minor if the consumer is between 13 and 16 years of age, or by the minor’s parent or guardian if the consumer is under 13 years old). Businesses must wait at least 12 months before asking consumers to opt back in.
Right to request deletion: Consumers also have the right to request the deletion of personal information, but only where that information was collected from the consumer. Like the right to erasure under the GDPR, this right is subject to exceptions. For instance, businesses need not delete personal information necessary for detecting security incidents, exercising free speech, protecting or defending against legal claims, or—in what is potentially a broad and likely contentious category—for internal uses reasonably aligned with the consumer’s expectations.
Right to equal services and prices: The CCPA prohibits businesses from discriminating against consumers by denying goods or services, charging a different price or rate for goods or services, providing a different level or quality of goods or services, or suggesting that they will do any of these things based upon a consumer’s exercise of any CCPA rights. Put differently, consumers have a right to equal services and prices.
Exercising your rights under the CCPA:
According the law (see paragraph above), you are entitled to request specific pieces of personal information (as defined under the CCPA) that we have about you, the business purpose for which the personal information was collected, categories of personal information, categories of sources from which the personal information was collected, categories of personal information that we either shared, transferred, sold with a business purpose, categories of those third parties to which the personal information was sold for a business purpose.
If you want to do such a request, you can write to email@example.com and we will respond within 45 days as per the law.
We reserve the right to verify your identity if you make such a request.
However, we may not be able to respond to your request if it goes against applicable law.
(Please note that we do transfer personal information collected through our network of partners to third parties and as such are considered as having disclosed or sold data (as defined under the CCPA) over the past twelve months.)
Opt-Out Request Form
Updated: January 8, 2020