Effective Date of Current Policy: December 31, 2022
Wunder is a member of the Internet Advertising Bureau and Network Advertising Initiative (“NAI”) and adheres to the 2020 NAI self-regulatory code, and the Digital Advertising Alliance self-regulatory code.
The Types of Information that We Collect and How We Use it
The Websites and our general business operations
Our Websites are directed to our Clients, partners and vendors which are generally businesses. We collect two types of information from visitors to our Websites: personally identifiable information and pseudonymous information. Personally Identifiable Information (“PII”) is information that may be used to identify an individual and includes email address, telephone number or postal address. Pseudonymous information doesn’t enable us to identify anyone but may help us recognize a particular browser or device over time. Both PII and pseudonymous information are considered personal data and/or personal information in many places. We believe that maintaining the distinction between what we consider directly identifiable and what we consider to be pseudonymous can be helpful in describing our privacy practices, but recognize that some privacy laws don’t distinguish between the two types of data.
We don’t generally knowingly collect sensitive or special category data such as ethnicity, religion, sexual interest, health data or data from minors as defined under applicable law other than in an employment context which is covered under a different policy. We ask our Clients not to send this type of information to us. Some places consider precise location to be sensitive. We don’t collect or otherwise process precise geolocation data (e.g., lat/long) but we may obtain more general GEO data such as postal code or city (e.g., when we infer such information from an IP address).
We also generally don’t collect PII via the Websites unless it is provided to us. For example, if you purchase our products or Services, we may request certain personally identifiable information from you on our order form. This includes contact information such as your name, email address, and address, as well as financial information such as a credit card number and its expiration date. We use this information for billing purposes and to fill orders. If we have trouble processing an order, we also will use this information to contact you. We do not sell this information and generally will only use it for the purpose it was provided.
In addition, if you contact us by email or otherwise provide your email address to us through our Websites, we may keep a record of your contact information and correspondence. We reserve the right to use your email address and any other PII that you provide to us to respond to your inquiries and to send you marketing materials for our own products and Services. We also reserve the right to share contact information you provide to us in connection with accessing certain content through our Websites (for example, webinars with industry partners) to our production partners or sponsors of such content. To the extent that such sharing of this data would be considered a sale under applicable law, we’ll provide a privacy notice and provide data subjects with the right to opt-out. We will not otherwise share your contact information with outside parties for the purposes of marketing other products and Services to you without your consent.
We also collect pseudonymous information via the Websites such as the name of your internet service provider, the IP address of the computer or device you are using, the type of browser and operating system that you use, the date and time you access our Websites, the website referrer address and other log file information. Like most websites, our Websites use “pixel tags”, “web beacons”, “cookies” and/or similar tracking technologies that allow us to track the actions of visitors to our Websites as described here. We use this information to help us improve our Websites and the products, Services, applications, content and features that we provide. We also enable third parties to collect pseudonymous data via the Websites. This process may be deemed a sale of information in certain jurisdictions, and we will provide a notice and provide the ability to opt-out of such sales in those jurisdictions. We reserve the right to aggregate information collected from visitors to the Websites for any purpose, including publishing aggregate statistics about our Clients’ and/or Websites’ visitors, counting and better understanding our site visitors and protecting our Websites from security issues or fraud.The Ad Serving Platform
The Wunder ad serving Platform is designed to process pseudonymous information from a particular Client’s websites, mobile applications and the Client’s data partners and does not intentionally collect PII. The type of pseudonymous information collected via the ad serving Platform includes IP address, browser type, operating system, Internet Service Provider, referrer address, the time/date an ad is served and the site or mobile app that the ad is served in addition to other log file information. This information is used to offer products and Services designed to help our Clients better understand how their websites are being utilized, draw insights on how to better engage Users on their sites, to deliver more relevant advertising messages based upon the User visits to their sites, and to provide Clients with ad delivery reports. Wunder operates the Ad Serving Platform as a “service provider” in that we only process such information as directed in writing by each Client.The Behavioral Automation Platform
The Behavioral Automation Platform is a marketing technology offering that enables our Clients to target ads and emails powered by data that each Client collects from direct interactions with its customers. Wunder processes email addresses and other PII such as telephone number via our behavioral automation Platform. We typically obtain this information from our Clients that collect it via online forms on Client owned websites. We use this data only as directed by each Client. Our systems may access this information automatically as each data point is entered by a user into a particular web form in accordance with applicable law. We combine this PII with pseudonymous information also collected via Client websites such as a Client’s User ID, mobile o/s advertising ID, hashed user emails and/or other pseudonymous IDs to help our Clients with conversion tracking, site optimization and conversion. We may also collect an email address and a Client’s User ID when directed by a Client (e.g., when a user clicks on a link sent by one of our Clients via the Client’s email service provider). Wunder and our Clients may also use this information to send targeted email and SMS marketing messages to our Clients’ customers and prospective customers. We only deploy messages as directed the applicable Client.
You can opt out of receiving any further marketing or promotional text (e.g, SMS/MMS) messages from Wunder at any time by replying “STOP” to any SMS message you receive from Wunder. For help, reply “HELP” to any SMS message you receive from Wunder. In addition to any fee of which you are notified, your mobile provider’s standard message and data rates may apply to the SMS message correspondence with Wunder according to your individual rate plan provided by your wireless carrier. Please consult your mobile service carrier’s pricing plan to determine the charges for browsing data and sending and receiving SMS messages. Under no circumstances will Wunder or Wunder’s affiliates be responsible for any SMS messaging or wireless charges incurred by you or by a person that has access to your wireless device or telephone number. If your carrier does not permit SMS messages, you may not receive the SMS messages.The Identity Platform
The Identity Platform is designed to enable our Clients to activate their data in and across any marketing channel. Our Clients provide us with their customer emails lists, and we hash the email address(es) for each customer into a pseudonymous ID. Our Clients may also provide us with demographic, purchase and site visit data for their customers, and that data is only used as directed by each Client. Where our systems see that same user visit Client digital properties via different browsers and devices, we process the hashed email addresses, cookie IDs, mobile advertising o/s IDs and other pseudonymous identifiers in order to help us understand whether two devices are likely to be used by the same User or household. For example, where a User opens an email and we are able to place a cookie on that User’s browser, we may be able to determine that this was the same User that had recently visited and logged into our Client’s website. Once we’ve established that linkage, we may use the information across Clients to enable Clients to more effectively recognize Users via these pseudonymous identifiers, and to enable Clients to leverage the data collected from their sites as well as their customer demographic data. This technology enables us to identify browsers and devices over time and across different websites via the Identify Platform while ensuring that each Client’s customer demographic and targeting data remain under the control of each individual Client. We also may enable Clients to leverage those pseudonymous identifiers to purchase advertising on the Wunder Performance Advertising Platform as well as digital media platforms owned and operated by third parties. We are careful to segregate this data to ensure that neither Wunder nor our Clients are permitted to use information collected across non-affiliated Client sites and apps to personally identify and/or re-identify individual Users.The Performance Advertising Platform
Wunder also operates a Performance Advertising Platform that enables our Clients to both create and utilize interest segments (e.g., frequent shopping, interest in fishing) from data collected across multiple non-affiliated websites or mobile apps in order to deliver more relevant ads to your browser or device. These segments are provided to us by Clients based on their customer interactions with each Client (e.g., visits to Client sites). The segments may also include data provided by third-party data partners. The segments are attached to one or more pseudonymous identifiers described below for the purpose of delivering, customizing and reporting on advertising messages purchased via digital media platforms.The Audiences Platform
The Audiences Platform is a personalization platform that acts as a central repository for Client marketing data and enables our Clients to activate that data to send marketing messages. Such marketing messages are determined by each client based on automated triggers (e.g., when a user abandons a digital shopping cart) as well as via recurring sends (e.g., monthly emails to a Client’s best customers). Wunder collects email addresses and other PII such as telephone number via the Audiences Platform and use this data as directed by each Client. Our systems may access this information automatically as each data point is entered by a user into a particular web form in accordance with applicable law. We combine this PII with pseudonymous information also collected via Client websites such as a Client’s User ID, mobile o/s advertising ID, hashed user emails and/or other pseudonymous IDs to help our Clients with conversion tracking, site optimization and conversion. Wunder and our Clients may also use this information to send customized and retargeted email, text (e.g., SMS/MMS) marketing messages to our Clients’ customers and prospective customers and we may use aggregate information to improve all of our Platforms, products or Services.Our Services Dashboard
Employees of our Clients (“Client Personnel”) may provide contact information, such as their name and email addresses, in the Services Dashboard. We may use such contact information to message those Client Personnel to inform them about new releases, new functionality or services, training or other events being offered by Wunder that may be of interest to users of our Services, to provide important information about the Services (such as dates and times for scheduled maintenance), and for other purposes consistent with our ability to provide our Services and keep our Clients informed about our Services.
Additionally, when Client Personnel access or use the Services Dashboard, we will track and collect usage data, such as the date and time they visited the Services Dashboard, what information and data have been accessed via the Services Dashboard and other interactions they may have with the Services Dashboard. Wunder may use such data to determine the performance of the Services Dashboard, analyze how users of the Services Dashboard are utilizing our Services, identify potentially fraudulent or malicious activity, and for other purposes consistent with our ability to provide our Services and maintain or improve the Services Dashboard.Profile Segments by the Wunder Platforms
The Wunder Platforms processes data to draw inferences about Users based upon website visits and mobile app usage. Some of our Platforms also help our Clients collect email addresses and telephone numbers. We use the collected information to help our Clients engage their site visitors and bolster their advertising programs. Some examples of behaviors which generate profiles include: whether or not a visitor has visited a particular website, purchased something from that website, interacted with certain ads or other features placed on the website and/or submitted their email address to the website. We don’t create profiles which are considered sensitive or high risk under applicable law, and we don’t sell data collected via our Platforms except as otherwise indicated. The profiles created by our Platforms enable our Clients to offer a more engaging experience when you visit their websites and help our Clients serve targeting advertising messages on other websites.The Tracking Technologies used by our Platforms and our Services
Our Platforms and our Services may utilize tracking technologies such as pixel tags, HTML5 cookies, HTTP cookies, web beacons, statistical identifiers, and mobile o/s advertising identifiers such as Apple’s IDFA, the Android Advertising ID and other pseudonymous information. For more information about cookies and web beacons, please visit allaboutcookies.org. Statistical identifiers are created when our systems read pseudonymous information about your computer or device, including the user agent, IP address, and the browser and operating system of your computer and device. Statistical identifiers enable our systems to determine within a reasonable level of certainty that they are encountering the same computer or device, including in environments where third-party cookies are not supported. If you want to see whether our Platforms are using a statistical identifier on the browser you are currently using, please visit https://optout.networkadvertising.org/?c=1#!/. If you would like to reset the value of this identifier, you may do so here. More information on this reset functionality under “choice mechanisms” below.How We May Transfer the Information We Gather to Third Parties
Generally, we will not disclose the PII that we collect through your use of our Websites or the Services Dashboard to unaffiliated third parties without consent. We reserve the right, however, to provide such information to our affiliates, employees, contractors, agents, service providers and designees to the extent necessary to enable them to perform certain services for us, including order fulfillment and Website-related services such as web hosting, to improve Website-related services and features, to perform maintenance services, to distribute advertisements and other marketing materials on our behalf and to host our data. Other third-party service providers used by Wunder include: a) cloud computer, data storage and file storage providers, b) email marketing providers, c) website and b2b sales analytics providers, d) customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, e) customer billing systems partners, f) login authentication providers to ensure that the logins to our systems are working efficiently, g) social media platforms for advertising and marketing purposes, h) outsourced computer programmers helping ensure our systems are operating properly, i) auditing, debugging and security vendors. These agents work on our behalf and use data only as directed by us under written agreements which outline how they may use such data and require that such third party agents provide at least the same level of privacy protection as we do.
Wunder may transfer data collected through Wunder’s Website, and our marketing activities to entities such as: (i) website analytics vendors, who collect cookie and website engagement information to help understand website performance, (ii) advertising vendors, who collect cookie and website engagement information to target relevant advertising, and (iii) email marketing and lead database vendors, who collect email address and other personal information to improve email marketing efforts. We also may transfer some of the data collected via the Services Dashboard to analytics vendors. Some of the transfers to these entities would constitute a sale or sharing of personal information under applicable law.
Our Platforms are designed to interact with a number of other affiliated technology platforms as described here. While we don’t operate a data marketplace, some of the transfers of data from the Platforms may be considered a sale of personal information under certain jurisdictions in the U.S. such as the state of California. For example, where we use the Identity Platform to create pseudonymous IDs to identify browsers and devices, we enable the use of those pseudonymous IDs across multiple Clients. Where we are acting as an agent (i.e., a service provider / data processor) for our Clients, we will transfer information as directed by such Clients. This collection and use is generally subject to our respective Clients’ privacy policies, not ours. We also reserve the right to disclose any information that we collect to any third party if we believe that we are required to do so for any or all of the following reasons: (i) to comply with the law; (ii) to comply with legal processes or governmental requests including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our Websites or our network; and/or (iv) to protect the rights, property, safety and security of Wunder and its employees, our Websites’ visitors, and/or the public. Finally, we may transfer information, including any PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change and will provide notice of such change on our Websites.
We also may aggregate the data processed by our Website and Platforms in order to derive insights across our Clients. For example, we may publish a report that reflects aggregated statistics regarding seasonal trends in shopping patterns or outlining differences between different retail verticals. By aggregating this data, we have removed any identifiable or pseudonymous personal data.Choice Mechanisms
Wunder supports high standards for digital privacy. We enable Users to opt-out from our our Identity Platform (including cross-device linking) and our Performance Advertising Platform as described below. Where our transfer of data to a third-party would be deemed a sale under applicable law, we offer a notice and the opportunity to opt-out from such sales.Web based Opt-Out Choice Mechanisms. You can opt-out of our Identity Platform and our Interest Based Ads Platform on your browser as follows:
You can opt-out of our Identity Platform and our Interest Based Ads Platform on your browser as follows:
- You can visit the Network Advertising Alliance self-regulatory opt-out page at https://optout.networkadvertising.org/?c=1#!/to opt-out and to see whether Wunder is using non-cookie based technology on the browser you are currently using. You should select the “opt out” button there for Wunder.
- You can visit the Digital Advertising Alliance self-regulatory program opt-out page at https://optout.aboutads.info/?c=2&lang=EN. You should select the “opt out” button there for Wunder. When our systems detect that you’ve opted out via this method, we will treat your opt-out request as a request for Wunder to stop collecting or processing data associated with this browser in accordance with EU data protection law.
- Some of the advertisements we deliver via the Services will contain the advertising option Icon, a symbol that we license from the Digital Advertising Alliance. If you click onto the advertising option icon, you will be taken to a page like this page where you will see behavioral advertising and other types of targeted advertising, including a mechanism that enables you to opt-out from Wunder’s use of data for targeted advertising.
- Each of the above opt-out mechanisms will also opt you out from Wunder’s sale as “sale” is defined under applicable law.
When you opt out via the web-based choice mechanisms described above, we will attempt to place an opt-out cookie that instructs us not to use information about your browser for IBA on our Identity Platform and our Performance Advertising Platform.
If your browsers are configured to reject cookies when you visit our opt-out page, we cannot set our no-track / opt-out cookie. Also, this choice mechanism is only applicable to the browser you are using, so if you subsequently erase your cookies, use a different computer or change web browsers, you will need to opt-out again.
Statistical device ID reset. Wunder may also create a non-cookie based system created pseudonymous identifier which is used enable are systems to more effectively recognize a browser over time. Information collected as outlined in “The Types of Information that We Collect” may be associated to this identifier over time. If you would like to reset the value of this identifier, you may do so here. Note that any new data collected after resetting your identifier may resemble data previously collected if you engage in similar activities on websites.
Mobile App Opt-out Choice Mechanism.Where we process pseudonymous mobile ad IDs, we honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). The NAI maintains a helpful list of opt-out mechanisms for mobile operating system platforms which you may find here. For devices where we are able to see that such a selection has been made, we will not use information collected about your mobile app usage on our Identity Platform and our performance advertising Platform. This choice mechanism is only applicable to the apps you are using on your current mobile device.
Precise Location Choices.While we don’t generally collect or otherwise process precise location data such as lat/long, we offer the following information as a courtesy. If you’d like to adjust your choices regarding the use of precise location data by third parties, you may do so via your device settings. For your convenience, we provide links to instructions for both Apple iOS and Android devices. Also, most mobile applications that collect precise location information offer mechanisms to control the collection and use of precise location information. Please note that these choice mechanisms won’t impact previously collected precise location information.
Some of our Clients may utilize third-party advertisers on their websites. These third-party advertisers generally collect pseudonymous information across multiple non-affiliated websites and mobile apps to create interest segments for ad targeting and content customization purposes. This practice is sometimes referred to as interest based advertising (“IBA”) or online behavioral advertising (“OBA”) and is distinct from the Behavioral Automation Platform and Identity Platform offered by Wunder. To learn more about third-party advertising companies and your choices regarding how that information is used, please visit https://thenai.org/opt-out/, https://optout.aboutads.info/?c=2&lang=EN or https://youronlinechoices.com/.
While our systems are able to recognize a Do Not Track (DNT) setting in a browser, we currently take no response to such signals.
Wunder ensures that text (e.g., SMS/MMS), email, and similar direct marketing messages sent using our behavioral automation Platform contain a choice mechanism as required by applicable law.Children's Privacy
Wunder adheres to the Children’s Online Privacy Protection Act. Our Websites are not directed at children. If we are made aware that we have received personally identifiable information from someone under 18, we will use reasonable efforts to remove that information from our records.We are Committed to Making Sure Your Information is Protected
Our physical, electronic, and procedural safeguards meet or exceed current industry standards regarding the protection of the information in our systems. We also require contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us. Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. Consequently, while we use commercially reasonable efforts to protect information in our systems, we cannot guarantee the absolute security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Websites or Platforms. Any information that you provide to us is done so entirely at your own risk.Data Minimzation and Retention
Wunder has internal procedures which are designed to ensure that we only process the minimum data as requested by Clients. We retain the IBA data that we collect for up to 13 months from the date of collection. Cookies used for IBA expire 13 months after they are last updated. EU data subjects may have additional rights or information as described below.Data Subject Access Rights
If we sell all or any part of our business or sell or transfer all or a material part of our assets or are otherwise involved in a merger or other transfer or disposition of any part our business, we reserve the right to access, transfer or disclose any and all information that we collect from our Websites’ visitors, or that we otherwise collect in connection with the Websites or Platform, to the party or parties involved in the transaction as part of that transaction.U.S. DATA SUBJECTS IN APPLICABLE STATES
Certain U.S. States each provide additional privacy protections for data subjects located within their jurisdictions, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete), c) the right to correct data we have about you, your computer or device, d) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information), and e) the right to port such data to a different company. We do not discriminate against you if you exercise any of the above rights. Moreover, with respect to data subjects in these places, PII (sometimes referred to as personal information) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. While we attempt to honor these rights for data subjects located in all U.S. states, please note that we may not be able to honor a right if doing so would otherwise violate applicable law. Further details about exercising these rights can be found on our data request page. Data subjects may access those rights with respect to Wunder by calling our toll-free California privacy hotline at (888) 594-0111 or sending us an email to firstname.lastname@example.org.
Below is the details about privacy requests received by Wunder in the applicable year:
|Requests to know||136||136||0|
|Requests to Delete||6,374||6,374||0|
|Requests to Opt-out||3,263||3,263||0|
The median number of days within which Wunder substantively responded to requests to know, requests to delete and requests to opt-out: 10 days, 10 days, and 10 days. However, requests to opt-out which are made via an opt-out link are honored in real time.Special Data Protections for EU, UK and Brazil Data Subjects.
The General Data Privacy Regulation (“GDPR”) and similar country specific data protection laws afford additional rights to data subjects located in applicable jurisdictions such as the European Economic Area, the United Kingdom and Brazil:
- requesting information about the processing of your data, as well as the receipt of a copy of your personal data;
- correcting your data;
- deleting or blocking your data;
- restricting the processing;
- objecting to the processing of your data;
- revoking your consent to the processing of your data in the future, and
- complaining to the competent supervisory authority about inadmissible data processing.
These rights can be exercised by visiting our data request page. Moreover, with respect to data subjects in these places, PII (sometimes referred to as personal data) includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. Where Wunder is a processor of data (e.g., via the Behavioral Automation or Ad Serving Platforms), the legal basis for processing such data and the retention period is determined by our Clients. Where Wunder is a controller of data (e.g., via the Performance Advertising or Identity Platforms to the extent we choose to operate those platforms in the EU), the legal basis will be both legitimate interest (e.g., where we have evaluated that our interests are not overridden by Users’ fundamental rights) and consent depending on the type of information subject to processing and the information we receive from upstream partners. Where Wunder receives a request to cease processing of data from a data subject located in the EU or Switzerland, Wunder will stop all data processing with respect to the opted-out browser or device unless such processing is required by law. Wunder’s Data Protection Officer is Alan Chapell and Wunder’s EU representative is Verasafe and both may be contacted at email@example.com or by mailing to the address found below. Wunder’s UK contact details are also provided below.Cross-border data transfers between the EU, Switzerland, UK and the U.S.
Attn: Privacy Officer
1 World Trade Center, FL 74
New York, NY 10007
Wunderkind Technologies UK:
16 Dufour’s Place
UK GDPR Representative:
General Manager, EMEA