Privacy Policy

Effective as of April 2nd, 2019

We have prepared this Privacy Notice to explain how, why, and when we collect data from you to provide targeted advertising services for our clients, and your rights in respect of this data. If you have additional questions, you can contact us at info@trepcamp.org

Please note that this Privacy Notice does not apply to data we collect when you visit another TrepCamp website, including www.trepcamp.org.

1. What data we collect

We collect the following categories of information for the purposes explained below.

  • Device and browser information:  Your device's IP address, cookie string data, operating system, and (in the case of mobile devices) your device type and mobile device's unique identifier such as the Apple IDFA or Android Advertising ID.

  • Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.

2. How we use the data we collect

We use this data to serve ads that may be relevant for you. We also use this data to operate, improve and enhance our services including enhancing the data points we or our Advertising Partners have about a particular user, browser, or device to serve the most relevant ads to you and, in turn, improve performance of an Advertiser’s ad campaigns. Specifically, we use this data for:

  • Targeting: Selecting ads that are more likely to be relevant to you based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads. For example, we may show you ads for your favorite shopping site (or similar sites we think you may like) during lunch or commute hours.

  • Frequency capping: Making sure that you don't see the same ad too many times.

  • Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.

  • Cross-device matching: Identifying all devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices. For example, cross-device matching helps us NOT show you ads for the shoes you were looking at on your phone but that already purchased on your tablet. Instead we’ll try to show you ads for an upcoming triathlon where you can put those shoes to work. It also helps us match devices so we can honor your opt-out choices across all devices we know are connected to the opted-out cookie.

Data is reported in the aggregate for the campaign and, at times, at the cookie level. For some customers, ad metrics are reported at the domain level at the contact level. For some customers, ad metrics such as impressions, clicks, conversions etc. are aggregated at the domain level (the domain representing the company/account the Advertiser wanted to target) as well as at the contact level (the individual to whom the ad is being targeted) represented with an email address that was initially provided by the Advertiser.

3. Our legal basis for processing personal data (European Territory Visitors only)

We provide the representations and information in this Section 4 in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). They are specific to persons located in EEA countries or Switzerland, so please don’t rely on the below, if you’re not in one of those countries.

If you are a visitor from the European Territories, our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it. "European Territories" mean the European Economic Area and Switzerland. For the purpose of this Privacy Notice, the term "European Territories" shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit.

However, we will normally collect personal data from you where the processing is in our legitimate business interests to, for example, administer our platforms and services and fulfil our contractual obligations as a service provider.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, then please contact us at www.trepcamp.org

4. Data Sharing

We may disclose information about you:

  • With an Advertiser whose Digital Properties you have visited: We may share information about how you have interacted with that Advertiser’s Digital Properties or its Ads.

  • With our service providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.

  • With service providers to our Advertisers: Our Advertisers may contract with companies who handle data (such as managing Advertisers’ customer lists) for them.

  • With Impulsa Business Accelerator and TrepCamp related companies.

  • In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of TrepCamp.

  • To Comply with legal process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.

  • To Investigate Wrongdoing and Protect Ourselves or Third Parties: To enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).

5. Cookies and related technologies

The TrepCamp Application platform uses cookies, tracking pixels and related technologies to provide ads that may be relevant to you. Cookies are small data files that are served by our platform and stored on your device.

Tracking cookies enable us to identify your device when you move between different Digital Properties, so that we can serve targeted advertising to you.

Specifically, we use the AdRoll cookie we serve through the AdRoll platform for this purpose is named “__adroll”.

We may also drop cookies from other Adroll’s Advertising Partners for the purposes described above. The Advertising Partner cookies dropped will vary depending on who the Advertisers are.

Additionally, we use non-tracking cookies (not unique) to store user decisions in terms of your ad and opt-out choices

  • We may drop an __adroll cookie with value opt-out if you opt-out as described below and an AdRoll consent cookie to track your consent choices.

  • We may drop a __consent cookie that stores the choices you have made regarding data processing and advertising by AdRoll.

6. Your choices and opting-out

We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:

  • You can opt out of receiving personalized ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by clicking here. Please note that this “opt out” function is browser-specific and relies on an “opt out cookie”: thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again.

  • In some cases we may link multiple browsers or devices to you. If you opt out of on a browser or device and we have more linked to you, we will extend your opt out decision to the other linked browsers and devices. Since we only link users across browsers on devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.

  • AdRoll Group is also a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing personalized ads from us and from other NAI approved member companies.

  • AdRoll also complies with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.

  • AdRoll comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.

  • We also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt out via their Your Online Choices website.

  • Please note that when using the ad industry opt-out tools described above:

    • If you opt-out your browser may still send us data, for example your IP address. However, AdRoll isolates this data and do not use it other than for accounting and, in some cases, for fraud prevention. If you have opted-out on that browser, we do not use this data to personalize ads or to track you.

    • If you use multiple browsers or devices we will additionally opt out those we have linked to you. Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt out on each browser or device.

    • Other ad companies’ opt-outs may function differently than AdRoll opt-out.

  • To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:

    • iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting

    • For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”

Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.

Some internet browsers allow users to send a "Do Not Track" signal to websites they visit. We do not respond to this signal at the present time.

In addition, if you are located in a European Territory you will also have additional data protection rights. These are described under the heading "Additional data protection rights for European Territory residents" below.

8. Data retention

We retain personal data we collect directly for targeting purposes until you asks us to delete it.

Personal data collected for other purposes is held no longer than necessary for our business purposes.

10. International transfers

We may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. In general, these countries will be the countries in which our service providers operate.

Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.

11. Additional data protection rights for EEA residents

If you are a resident of a European Territory, you have the following enhanced rights under EU data protection law:

  • If you wish to access, correct, update or request deletion of your personal information, you can contact us at info@trepcamp.org

  • You can object to processing of your personal information, ask us to restrict processing of your personal information. Again, you can exercise these rights by contacting us using to info@trepcamp.org

  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

12. Changes to this Privacy Notice

Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on the site or by other means as appropriate.

If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

13. Contact us about questions or concerns

If you have any questions about this Privacy Notice or our privacy practices, you can contact info@trepcamp.org

TrepCamp

Impulsa Business Accelerator

23180 Ravensbury Ave, Los Altos Hills, CA 94024, EE. UU.