Xywrite is a New York-based advertising technology company that provides a service to consumers, website publishers, and other advertising companies by providing — and allowing other companies to provide — consumers (“Users”) with relevant ads on their computers and mobile devices.
Xywrite is a member of the Network Advertising Initiative (“NAI”) and follows the Code of Conduct. Xywrite also complies with the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising.
Information about our data collection during the prior 12 months is described below.
You can access, delete and control certain uses of your information as set forth in the “What other rights do I have to my personal information?” section below.
- Information that is lawfully made available from federal, state or local government records.
- Deidentified or aggregated information.
- Information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
What types of information does Xywrite collect?
In order to increase the relevance of online advertisements, our technology collects information about users as they visit websites that partner with us. Xywrite typically collects this information when a User visits a website where our technology is used or enters a word or phrase into a search engine or conducts a search for a product or service where our technology is used. Xywrite also collects data provided by select data partners, including demographic information (e.g., area code, city, gender, age), life stage data, and business-to-business data. This data may have been originally collected either online or offline. Xywrite also collects information about users’ mobile devices, including the advertising identifiers assigned to their devices (on iOS devices, the IDFA, and on Android devices, the Advertising Identifier) from its data partners, and may associate those identifiers with data that it collects directly and other devices it has associated with you.
Xywrite stores, uses, and may share both raw search terms and websites visited as well as segment categories inferred from such raw data to help deliver relevant online advertisements. For example, if a User searches for a “digital camera” on a partner web site of Xywrite, Xywrite will store and use the term “digital camera” in its raw form and to inform the segment categories associated with the user (e.g., “electronics”).
Xywrite does NOT intentionally collect or store any data that can be used to directly identify a User such as name, address, telephone number, social security number or e-mail. We do not attempt to identify Users using the information we collect, and we forbid our partners from using the data we share with them to attempt to identify a User’s real-life identity. We do collect, store, and share personally identifiable information that has been hashed so that it does not identify a User.
While Xywrite does not create nor provide any sensitive data segments to our partners for the purpose of helping them to tailor ads, we recognize that consumers may have differing opinions regarding which data segments are sensitive. In order to provide transparency around potentially sensitive data segments collected and used by Xywrite and the partners with whom we share collected information, we will provide examples of them here: (1) we may collect wellness-related segments such as users who search for fitness and exercise in order to create health segments (but we do not use sensitive health information to create such segments); (2) we may also collect financial related segments such as users who search for investing and loans; and (3) we may use information on party affiliation or views on issues to create political segments. While we don’t consider any of the above data segments to be sensitive, we think it’s important to provide this transparency to help you have a better idea of which segments might be collected by us, so you can make informed decisions.
How is the information collected through Xywrite technology used?
This information we collect is used to provide advertisements about goods and services that may be of interest to you on the websites and mobile apps you visit on the device from which we collect data and on other browsers and apps that we have associated with you. These relevant advertisements are delivered either directly by Xywrite or by Xywrite’ partners based on information provided by Xywrite to them. The information may also be used by third parties to whom we sell or transfer the information for purposes of their products and services, such as research, fraud detection, financial services and other lines of business.
We may use your information to match it with other public and private data sources in order to enhance our records, such as appending additional information to your profile, or the records of our clients and business partners, such as providing them with your profile information to append to their existing records about you.
How do I know if Xywrite collects data on a website I visit?
We require our partner websites to inform Users about their privacy and information collection practices, including whether or not the website partners with third parties like Xywrite to collect and use data for advertising purposes, and a way to opt out from the use of such data for targeted advertising purposes by Xywrite. Xywrite is a member of the Network Advertising Initiative (“NAI”) and follows the NAI’s Code of Conduct. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.
To whom is the information you collect disclosed?
Xywrite discloses the information collected by our technology on a limited basis, including the following:
- We share the information we collect with our advertising partners so they may deliver relevant online advertisements to users. We contractually require our advertising partners not to transfer this information to anyone else, not to merge it with Users’ names, email addresses, or other information that directly identifies them, and not to use this data beyond a defined period of time.
- We may grant our partner websites and advertising partners access to reports that aggregate information about the ads presented by the Xywrite system. The information in these reports does not identify anyone personally.
- We may also disclose to third parties the information we collect through our technology when we have a good faith belief that it is necessary to do so in response to legal process, to protect and defend Xywrite’ rights or property, to prevent fraud or in cases of imminent danger, or in the event of a merger, acquisition or sale of all or a part of Xywrite’ assets.
Does Xywrite sell my personal information to other parties?
Xywrite may sell your personal information to third parties, subject to your right to opt-out of those sales (See “What other rights do I have to my personal information?”).
In the preceding twelve (12) months, Xywrite has sold the categories of personal information in the chart set forth above.
How long do you retain the information you collect?
We generally store demographic information (e.g., area code, city, gender, age) obtained from our data partners for up to five years. After five years, demographic information is discarded.
We store search terms and segment categories for up to 5 years. After 5 years, search terms and segment categories are discarded.
What are your security procedures?
The security of the information collected through Xywrite’ technology is important to us. Information collected by the Xywrite system is stored in databases that are maintained in a secure data center in the United States. Both physical and Internet access are strictly protected and limited. Access is granted only to those with authorization. No method of transmission over the Internet or of electronic storage is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect the information we collect, we cannot guarantee its absolute security.
How can I opt-out from interest-based advertising by Xywrite?
If you would like to opt out from receiving ads that are made more relevant to your interests by Xywrite, you may do so by visiting the Network Advertising Initiative’s Opt-Out page and selecting Xywrite. You may also opt out of interest-based advertising by other members of the Network Advertising Initiative on this page.
If you choose to opt out, we will place a Xywrite opt-out cookie on your browser and we will no longer allow the information we collect to be used for interest-based advertising purposes on the browser where you opt out.
In addition, your mobile device gives you the option to opt out of the use of information about your mobile app usage collected by our data partners for purposes of showing ads that are more likely to be of interest to you. For iOS devices, you may opt out of such collection by turning on the “Limit Ad Tracking” flag in the Advertising subsection of the Privacy section of your Settings. For Android devices, select the “Opt-out of Interest-Based Ads” or “Opt out of Ads Personalization” in the Ads section of the Google Settings App. For more information on how to configure the settings on these and other devices,
Please note that each opt out is specific to the browser or device where it is exercised, and you will need to repeat these processes on every browser or device where you wish to opt out.
We use non-personally identifying information to facilitate cross device association. We or our third party vendors analyze device activity data using a mathematical tool known as a “probabilistic algorithm” to determine if you have interacted with content across multiple devices and to match such devices. In connection with this analysis, we may rely on non-personally identifiable information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies or we may use the non-personally identifiable information we collect in conjunction with such third party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their website or mobile applications are used and to further enable the display of targeted advertisements to you, including across your devices. Our advertisers may also provide us with deterministic data about you that may be used to supplement our probabilistic data. Based on this data, we and/or our clients may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their website or mobile applications are used and to further enable cross-device targeting and analysis. In order to restrict our use of certain cross-device data, you may opt out in accordance with this section or the “What other rights do I have to my personal information?” section below.
What other rights do I have to my personal information?
If you reside in California, under the CCPA, or have similar rights by law in your jurisdiction, you have specific rights regarding your personal information. This section describes such rights that you have and explains how to exercise those rights.
- Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that Xywrite disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, and Deletion Rights), and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following:
o The categories of personal information we collected about you.
o The categories of sources from which the personal information is collected.
o Our business or commercial purpose for collecting or selling that personal information.
o The categories of third parties with whom we share that personal information.
o The specific pieces of personal information we collected about you
- Right to Request Deletion. You have the right to request that Xywrite delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting as illegal activity.
- Exercising Access and Deletion Rights.
To exercise the access and deletion rights described above, please submit a request to us via email to firstname.lastname@example.org or call 1 800-569-8627.
Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. You may also make a request on behalf of your minor child.
The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information (including cookie ID and/or Mobile Advertising ID that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative.
We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing.
In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We are not obligated to provide the information set forth above under “Right to Know About Personal Information Collected, Disclosed or Sold” more than twice in a 12-month period.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights. You have the right to direct us to not sell your personal information at any time (the “right to opt-out”). To exercise your right to opt-out, click here. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age.
- Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by:
o Denying you goods or services.
o Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
o Providing you a different level or quality of goods or services.
o Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How can I learn more about Xywrite’ Privacy Practices?
You may contact Xywrite with any questions or concerns you may have at:
37-21 Northern Blvd, Suite 404
New York, NY 11101
Tel: (646) 867-0648
UNITED STATES OF AMERICA: Our servers are maintained in the United States of America. By using the website, you freely and specifically give us your consent to export your personally identifiable information to the USA. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.