Effective Date as of December 18, 2015
Gupta Media acknowledges that our clients share confidential and valuable information with us. Gupta Media further acknowledges that clients share that information in order for us to better target, track and measure the performance of their digital & mobile marketing campaigns.
The data shared typically falls into two categories:
Personally Identifiable Information (PII) typically includes email address, phone numbers and other contact information that can be used to match an online user.
Clients should not share other PII such as health and medical records, social security number, place of birth, mother’s maiden name or other biometric records. Gupta Media is not HIPAA-compliant.
Non-personally Identifiable Information differs from PII in that we are able to identify a browser/ device, but not the user specifically. Retargeting lists, web analytics, custom audiences, tailored audiences generally fall into this category. Non-personally Identifiable Information is the majority of the data that we have access to, the least sensitive, and the least valuable outside of each platform’s own toolkit.
Gupta Media endeavours to be a guardian of our client’s data and to only use the data to further the specific client’s business goals, specifically in the following ways:
1. Retargeting lists will be used to identify past website visitors and encourage them to take further action. Retargeting lists will also be used to identify users who have taken a given action and remove them from the target audience (“negative match”).
a. Google Remarketing
b. Facebook Website Custom Audiences
c. Twitter Tailored Audiences
d. Google Analytics
2. Email addresses and mobile phone numbers will be used as a common key to match users in different systems. This contact information will be hashed in browser before being sent to these systems in order to protect against reverse engineering which could reveal that data.
a. Facebook Custom Audiences
b. Twitter Tailored Audiences
c. Google Customer Match
3. Client data can be used by Gupta Media as a research tool to help understand the demographics of the client’s target audience. Additionally, Gupta Media uses data to create benchmarks and comparison sets.
Gupta Media specifically acknowledges that it does not:
1. Combine multiple client’s data to create behavioral segments.
2. Allow a client to leverage another client’s data.
3. Sell a client’s 1st-party data to data aggregation firms, fusion centers, etc.
4. Use a client’s data in future campaign, without reaffirming client consent.
5. Contact users from client’s data in ways other than paid digital advertising.
6. Add client’s data to Gupta Media’s internal databases.