TowerData, Inc. (“TOWERDATA,” “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 collect information on our website, both when it is voluntarily provided by website visitors and in some cases when we use technologies (like cookies) to automatically collect information. We discuss that information, and how we use and share it below.
The domain name and IP addresses of users’ web browsers.
Aggregate information on what users access, utilize or visit.
Information, including PII, voluntarily provided by you, such as survey information, requests for information, mailing addresses and email addresses.
Credit card or payment information, and any personal information related to it, if we provide a way to pay for our services online.
We use the Information we collect through our website(s) to do the following:
Create and manage your unique user account.
Provide services to you.
Respond to and communicate with you (including regarding news and updates about our services).
Send you offers and ads for our products and services, when you browse the website(s) or other companies’ websites on the Internet.
Perform data analyses (including market research).
We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of our products and advertisements.
We may use IP addresses to help diagnose problems with our servers and to administer our website(s). We also may use IP addresses and cookies to help identify visitors to our website(s) for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our website(s), how visitors navigate through the website(s), and how we may tailor our website(s) to better meet the needs of our visitors.
We also use the Information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.
We may share the Information with service providers, such as credit card processors, who help us deliver the services you request or we provide.
We may share the Information with service providers we use to communicate with you and market to you, including through email, direct mail or display media.
We will disclose your PII (or other information) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process.
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. And we may also collect certain information when you visit our website(s) or our marketing partners’ website(s).
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.
TOWERDATA 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).
TOWERDATA uses the Information to provide its services, including those described on this websites. 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.
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.
Residents of the EU may have additional choices with respect to the Personal Data we process about them. Please see below Section 12 on European Data Protection and Data Transfer for more details. You may click here to opt-out of TOWERDATA’s marketing services platform. When you opt out, we will cease sharing your Information with partners and clients for marketing purposes; however, opting out in this way will not immediately affect information that has already been passed to those partners or clients.
TOWERDATA 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 TOWERDATA 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.
Affiliates, parent companies and subsidiaries: TOWERDATA may share some or all of the Information with affiliated or subsidiary companies.
As Required by Law or to Protect Any Party: TOWERDATA 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 TOWERDATA or any other party.
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.
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.
This website may provide links to other websites that TOWERDATA thinks users will find interesting or useful. TOWERDATA is not responsible for the privacy practices of these other sites or companies.
TOWERDATA 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. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts to ensure that this does not occur.
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.
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.
TowerData is a business-to-business website and is not directed to children under the age of 13. Similarly, TowerData'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.
a. European Law and the GDPR
As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) will be in effect, through the EEA countries. The GDPR (and other European privacy laws) make a distinction between organisations that process Personal Data for their own purposes (known as “data controllers”) and organisations that process Personal Data on behalf of other organisations (known as “data processors”). The GDPR requires companies that are “Data Controllers” (which includes some of our clients) provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data.
We sometimes process Personal Data relating to data subjects (i.e., persons) on behalf of these clients, and we therefore often enter into agreements to assist them in complying with their own obligations under the GDPR. However, if you have a question or complaint about how your Personal Data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.
On the other hand, we are data controllers of Personal Data that we collect from our own website, and from our own customers. As to that data, please note the following :
(i) We rely on performance of our contracts, and our legitimate interests, as a legal basis for our processing of the data that we control. For instance, when we process and retain our customers’ Personal Data, or send information to companies that we believe are interested in our services, we rely on these legal bases;
(ii) We retain the data that we control for as long as is necessary or appropriate to fulfill the purpose for which the data was collected;
(iii) You may request access to, or deletion or correction of, the Personal Data that we hold about you by contacting us through the contact information listed in Section 13. If you request that we delete your Personal Data, we will remove you from our marketing lists, but will continue to maintain certain Personal Data where we have an important legal, accounting, billing or auditing reason to do so.
b. Data Transfer and Privacy Shield.
We self-certify compliance with Privacy Shield as to data that we process on behalf of our clients. You may view our certification through the “look up” features here: https://www.privacyshield.gov/list
If you are a resident of the European Union or Switzerland and are dissatisfied with the manner in which we have addressed your concerns, you may seek further assistance, at no cost to you, from our designated Privacy Shield independent recourse mechanism, the DMA Privacy Shield Program, which you can learn more about by visiting https://thedma.org/resources/consumer-resources/privacyshield-consumers/. Residents of the European Union or Switzerland may elect to arbitrate unresolved complaints but prior to initiating such arbitration, you must: (1) afford us the opportunity to resolve the issue; (2) seek assistance via TowerData’s recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual.
We self-certify compliance with Privacy Shield - https://www.privacyshield.gov/list
If you have questions related to this policy, or regarding TOWERDATA’s products or services, please contact us at:
33 Irving Place
New York, NY 10003
Last updated: Dec. 28, 2018