Privacy Policy

Effective as of March 1, 2016


Introduction

1trn LLC is a global provider of digital media and data management technology for advertisers and agencies. 1trn’s platform (the “Platform”) activates data, automates execution, and optimizes advertising interactions across addressable media—delivering greater performance, transparency, and control to marketers and a better experience to consumers.
This Privacy Statement presents 1trn’s privacy policy, including privacy practices for data choice, use and collection via our Platform and on the www.1trn.com website (the “Website”).


The 1trn Platform

1trn is strongly committed to protecting the privacy of internet users. Accordingly, we adhere to applicable industry guidelines, and will continue to review and update our privacy policy and procedures to ensure the safety and protection of consumer information.
1trn complies with the DAA Self-Regulatory Principles for Online Behavioral Advertising and their Application to the Mobile Environment, and the 2015 NAI Code of Conduct.


Platform Data Collection and Use

At 1trn, we think it’s important to provide transparency so that you have a better idea of which data we might collect and can make informed decisions.
In the course of delivering an ad to you via the Platform, 1trn does not collect data such as your name, address, phone number, or social security number. 1trn collects data about your device that is considered non-personally identifiable and pseudonymous in most jurisdictions in which we operate. In certain contexts and jurisdictions, Internet Protocol (IP) addresses and other pseudonymous information may be considered personal data.
1trn uses this information to target ads and measure the effectiveness of ads on behalf of 1trn’s advertisers. This information includes common information found in every communication sent over the internet, from which we can often infer such things as:

  • Browser type (e.g., Chrome or Internet Explorer)
  • Operating system (e.g., Mac OS or Windows)
  • Browser language (e.g., English or Spanish)
  • Internet Protocol (IP) address
  • Internet Service Provider (e.g., Comcast or Verizon)
  • Mobile advertising identifier, for mobile devices such as smartphones and tablets

1trn may also collect data regarding your interactions with our clients and partners, including your use of our clients’ sites and mobile apps, the sites and apps our clients advertise on, and other pages on the internet. We may also capture additional data in order to calculate a statistical ID, as described below.
1trn may use this non-personally identifiable and pseudonymous data to create data segments, and these data segments are generally based upon your interactions with our clients such as the websites that you visit and the mobile applications that you use. 1trn also receives information from third-party data providers that create non-personally identifiable behavioral, contextual, and demographic segments for our clients to use in targeting ads through the Platform.
1trn does not collect data or create data segments that are based upon what we consider to be sensitive information (for example, we don’t use any data segments to determine credit worthiness, for insurance underwriting or similar purposes).


Cookies, Web Beacons, and Other Ad Targeting Technologies

Like most digital marketing platforms, 1trn uses mobile advertising identifiers, and other technologies to enhance users’ experiences on the web, to deliver more relevant ads, and for ad delivery and reporting via the Platform.
1trn cannot use these technologies to personally identify you. We use these technologies to help recognize a unique device so that 1trn and our clients are able to deliver relevant advertising, measure the impact of that advertising and better understand and recognize digital media usage patterns. Your browser or mobile device is assigned a unique 1trn ID the first time 1trn serves an ad to it or identifies it on a client’s website. This unique ID may be stored in a file on your mobile device. Along with the other information we collect via the Platform as described above, this unique ID helps us deliver more relevant ads to you. The ID and other information collected via the Platform can also help our advertising clients measure your activity on their sites and determine the effectiveness of advertisements delivered via the Platform. This information can then be used by our advertising clients to better cater to your needs and deliver to you ads for the types of products in which you might be interested. None of these technologies enable us to personally identify an individual. Instead, they enable the Platform to determine within a reasonable level of confidence that the device we served an ad to on Monday may be the same device on which we observed a purchase on Tuesday.
The types of technologies used via the Platform include:

  • Mobile Advertising Identifiers – Mobile advertising IDs are unique, non-PII IDs associated with individual mobile devices. They usually are user-resettable.
  • Pixel Tags – Pixel tags (also commonly known as web beacons) are transparent images, iFrames, or JavaScript that our clients and partners use to understand how consumers interact with them online, including on websites and in mobile apps.
  • Statistical IDs – Statistical IDs are created via an algorithm using non-personally identifiable and pseudonymous information about your device, including your operating system, user-agent string, IP address (in jurisdictions where this is not considered to be personal data), internet browser, installed fonts, and similar information. This information makes your device distinct enough for our systems to determine within a reasonable probability that they are encountering the same device, including in environments where 1trn cookies are not supported.

None of these technologies, whether individually or as a whole, are used via the Platform to identify individual people. Rather, they are used to uniquely identify a device within a certain level of confidence that enables the Platform to function and serve more relevant ads.


Data Retention – How Long is Data Stored on the Platform?

Cookies set via the Platform expire after 13 months or less. After 13 months, we expire the unique ID and targeting segments that are associated with your browser or device.
1trn retains log-level data in the Platform for up to 13 months and maintains aggregate data (which cannot be associated to any individual device) for up to three years.


Consumer Opt-Out

What does it mean to opt-out?

In general, “opting out” means that you don’t want 1trn to deliver ads that are targeted to your interests on your device. If you use multiple browsers or mobile devices, you must opt out of each individually. Please note that if cookies are not enabled in your browser, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly.
Please also note that deleting your cookies does not equate to opting out.

Web-Based Opt-Out Mechanism:
Click here to opt-out.

Please note that you will still see ads if you opt out. The ads delivered via 1trn will just not be as relevant to you.
When you opt out, we record the opt-out on our servers and in browser environments will attempt to place an HTTP opt-out cookie onto your device. When you opt out, 1trn also stops serving interest-based advertising on that browser or device. In many instances, even if you delete your cookies, we are able to maintain a record of your opt-out on our servers. Nonetheless, please note that if you clear your cookies, or if you use a different browser or device, you may need to renew your opt-out choice.
If you have questions, please contact us at [email protected]


Disclosure

1trn reserves the right to publish or otherwise make public anonymous, aggregate, or summary information regarding users and campaigns run on behalf of our clients. We may share user-level data with clients. There also may be instances when we disclose information in our systems in order to: protect the legal rights of 1trn or its employees, agents and contractors; protect the safety and security of users and visitors to our Website; protect against fraud; or to comply with the law or legal process. If 1trn sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer information in our systems to a third party as part of that transaction.


The 1trn Website, www.1trn.com

Data Collection and Retention on our Website

1trn only collects personal information on our corporate Website when visitors choose to reveal it to us. For example, when you contact us to request a demonstration of our products or services or to otherwise send us questions, we will collect personal information such as name and email address. 1trn uses non-personally identifiable and pseudonymous information from the Website log files to determine how you found out about us, what your interests are regarding our services, and how to further improve our site and our service towards you. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Cookies set via the Website expire after at most two years.


Communications From the Site

When you sign up for our services on the Website, we will use your name and email address to send newsletters to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us via email at [email protected]


Service Providers

When you sign up for our services on the Website, we may provide your information to companies that provide services to help us with our business activities, such as an email service provider to send emails on our behalf or a recruitment partner to process job application data. These companies are authorized to use your personal information only as necessary to provide these services to us.


Technologies Used on the Website

Technologies such as cookies, beacons, tags, and scripts are used by 1trn and our partners (such as service providers), affiliates, or analytics or service providers (e.g., video providers and email service providers to send email on our behalf). These technologies are used in analyzing trends, administering the Website, tracking a visitor’s movements around the Website and to gather demographic information about our Website visitors as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.


Social Media Features and Widgets

The Website includes Social Media Features, such as the Facebook Like button, and Widgets or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on the Website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.


Testimonials

We display testimonials from satisfied clients on the Website in addition to other endorsements. We obtain client permission to place these testimonials on the Website. If you are a client who wishes to update or delete your testimonial, please contact us at [email protected]


Public Forums

The Website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at [email protected] In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.


Consumer Choice and Access

1trn will allow an individual access to their personal information to the extent it is available and allow the individual to correct, amend, or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question, or where the rights of persons other than the individual would be violated. If you’d like us to update, correct, delete, or deactivate any other personal information that you have provided to us, please send your request to us at [email protected] and we will respond to your request within 30 days.


Additional Information Applicable to our Website and Platform

Information Pertaining to Children

1trn’s products and services are designed for those 13 years of age and older. We do not knowingly collect personally identifiable information from anyone under the age of 13. If the company is made aware that it has received personally identifiable information from someone under 13, we will use reasonable efforts to remove that information from our records.


Security and Data Integrity

1trn uses commercially reasonable measures to safeguard data in our possession against loss, theft, and unauthorized use, disclosure, or modification. No transmission of data over the internet, however, is guaranteed to be completely secure. It may be possible for third parties not under the control of 1trn to intercept or access transmissions or communications unlawfully. While we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us. 1trn processes information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current, and reliable for its intended use. If you have any questions about security on the Website or through the Platform, you can contact us at [email protected]


Policy Revisions

From time to time 1trn may revise this privacy policy. If we make revisions that change or affect whether or how we collect or use personally identifiable information we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this site prior to the change becoming effective. Therefore, you should review it periodically so that you are up-to-date on our most current policies and practices.


Links

This privacy statement applies solely to the Platform and Website of 1trn. 1trn’s Website contains links to other sites, and the ads delivered by the Platform may run on a variety of other sites. Please be aware that 1trn is not responsible for the privacy practices of such other sites. We encourage our visitors to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information.


Re-Targeted Advertising

We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies, pixel tags, and other ad targeting technologies to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.


Enforcement, Questions and Complaints

Enforcement:

1trn has implemented processes to ensure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible. We encourage interested persons to raise any concerns by emailing [email protected] and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.


Privacy Complaints by European Union Citizens:

In compliance with the US–EU and US-Swiss Safe Harbor Principles, 1trn commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss citizens with inquiries or complaints regarding this privacy policy should first contact 1trn at [email protected] or you can send correspondence to the following address: 1trn LLC, Attn: Privacy, 801 South Flower Street, Suite 525, Los Angeles, California, 90017.
1trn has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by the Privacy Officer at 1trn, please visit the BBB EU SAFE HARBOR website at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.