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WealthPilot Advertising Privacy Policy

Policies Overview General Privacy Policy Services Privacy Policy Customer Data R&D Privacy Policy Advertising Privacy Policy

1. INTRODUCTION

This WealthPilot Advertising Privacy Policy (also referred to as the ‘Privacy Policy’ or the ‘WealthPilot Data Cloud Privacy Policy’) informs consumers (‘you’ or ‘your’) on the collection, use, sharing, and selling (collectively referred to as ‘processing’ or ‘process’) of your personal information in connection with WealthPilot’s provision of WealthPilot Advertising services designed to help WealthPilot’s customers’ and partners’ online and offline marketing activities (‘WealthPilot Advertising’). This Privacy Policy also explains your privacy rights in relation to these processing activities.

This Privacy Policy was last updated on June 7, 2023. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another way (for example, via a pop-up notice or statement of changes on our website).

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, past purchase behavior or information regarding your online interests. Personal information about you that WealthPilot may process is also referred to as ‘information about you.’

2. SCOPE

The Privacy Policy applies to WealthPilot’s processing of information about you provided to WealthPilot Advertising by our third-party data suppliers to help enable WealthPilot Advertising customers and partners to market products and services to you based on your interests.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

WealthPilot and its affiliated entities are responsible for processing your personal information described in this Privacy Policy.

4. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?

Information about you may in some cases directly identify you, while in other cases it may only indirectly identify you. Personal information that is collected offline and that can directly identify you may include, for example:

name, physical address, email addresses, and telephone numbers;
demographic attributes, when tied to other information that identifies you;
transactional data based on your purchases, when tied to other information that identifies you;
company data such as the name, size, and location of the company you work for and your role within the company;
data from marketing opt-in lists, consumer surveys, or publicly available information;
derived latitude/longitude from a physical address.

Personal information that is collected online and that may indirectly identify you may include, for example:

unique IDs such as a cookie ID on your browser;
Addressable media identifiers (“AMI”) or other partner- or industry-specific identifiers;
IP addresses and information derived from IP addresses, such as geographic location;
information about your device, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, or the preferred language;
obfuscated personal information such as hashed email addresses (direct identifiers are removed);
demographic information such as gender, age, and income range when not tied to information that directly identifies you;
behavioral data of the internet connected computer or device you use when interacting with websites, applications, or other connected devices, such as advertisements clicked or viewed, websites and content areas, date and time of these activities, or the web search used to locate and navigate to a website.

We may associate personal information about you with interest segments or profiles as part of the provision of WealthPilot Advertising services to our customers and partners:

Interest Segments are a specific group of consumers that share a common behavior or preference used for direct marketing by our customers. For example: in market for travel specials to Hawaii.
Profiles are a set of attributes about a specific consumer or device, or a set of multiple consumers or devices sharing common attributes used for marketing by our customers. For example: age bracket 25-55; adventurous traveler; surfing enthusiast; in market for travel specials to Hawaii.

5. FOR WHAT COMMERCIAL OR BUSINESS PURPOSE DO WE USE YOUR PERSONAL INFORMATION?

We use personal information for the following commercial purposes:

to provide Advertising services to WealthPilot customers and partners designed to enable them to market products and services to you based on your interests;
to analyze, develop, improve, and optimize the use, function and performance of WealthPilot products and services;

We use personal information for the following business purposes:

to manage the security of our sites, networks and systems;
to comply with applicable laws and regulations and to operate our business.

These purposes are described below in further detail.

a) For personal information collected from individuals: to provide Advertising services to WealthPilot customers and partners designed to enable them to market products and services to you based on your interests

We process personal information about you for marketing purposes to provide Advertising services to WealthPilot customers and partners designed to enable them to advertise products and services to you via online and offline marketing activities based on your interests. “Marketing purposes” means the processing of offline and online personal information, as defined in Section 4: (i) to solicit or induce a purchase, rental, lease, or exchange of products or services directly to consumers or businesses via offline and online advertising campaigns; (ii) to develop market research or market surveys or to provide verification services to marketers; (iii) to create, communicate, deliver, and exchange offerings that have value for customers, clients, partners, and society at large; or (iv) to encourage safe practices and trends and the provision of factual information, including, by way of example, providing product or automotive recall notices.

More specifically, WealthPilot can process information about you:

For online interest-based advertising delivered through WealthPilot Advertising partners that display online advertising to you on behalf of WealthPilot Advertising customers.

Example: a marketing professional working for a travel company wants to market the company’s travel specials to Hawaii to a specific group of individuals (also known as an audience) that may be interested in those specials. The marketing professional uses WealthPilot Advertising services to create an audience interested in travel to Hawaii. If you have visited a travel website previously and have expressed an interest in Hawaiian vacations, you may be placed in the travel company’s audience and subsequently see advertisements for a vacation to Hawaii on other websites (because a cookie has been placed on your browser) or, in the United States, via a connected device (due to an association between your IP address and device identifier).

For offline and online campaign measurement, analytics, and development of insights on behalf of our WealthPilot Advertising customers.Example: a marketing professional working for a travel company wants to better understand if the company’s marketing campaign for travel specials to Hawaii contributed to an increase in their product sales. The marketing professional uses WealthPilot Advertising services to see how many display or videos ads were viewed, and whether the ads were clicked on and a purchase was made.
For enabling our WealthPilot Advertising customers to personalize their products and services, including site optimization, email personalization, and dynamic marketing and advertising optimization.Example: if you have previously indicated an interest in travel to Hawaii, when you visit a travel company’s website it can display tailored offers for Hawaiian vacations on their homepage.
For linking Profiles and Interest Segments to enable WealthPilot Advertising customers and partners to connect your Interest Segments across the various browsers and/or devices you may use for the purposes described in this section.Example: you are interested in vacations offered by a travel company and have clicked on their online advertising. You are logged into several devices (your desktop, smartphone, and tablet) using the same login. WealthPilot Advertising partners have indicated that you are likely the same user across those same devices. The travel company is able to display vacation offers to you (via a de-identified cookie ID) on these different devices.
For creating modelled online and offline “lookalike” audiences for WealthPilot Advertising customers’ products and services.Example: a marketing professional working for a travel company wants to find new potential customers who are, like you, likely to be interested in travel to Hawaii. WealthPilot Advertising services can help the travel company by looking for key characteristics between Profiles that have expressed an interest in traveling to Hawaii and other Profiles where a similar interest can be inferred based on these characteristics, such as an interest in travel to tropical islands.
For enabling our WealthPilot Advertising customers to associate first-party information to certain WealthPilot Advertising identifiers in order to deliver marketing and advertising services to you.Example: A travel company has its own lists of customers who have purchased travel arrangements with them, with names, emails, and addresses. The travel company wants to be able to reach out to these customers with online advertising. The WealthPilot Advertising services can help the travel company by converting the company’s own customer lists from identified names, emails, and addresses, to de-identified groups of cookie and device IDs provided by WealthPilot Advertising, in a process known in the advertising industry as “onboarding”.

b) For personal information collected from individuals: to analyze, develop, improve, and optimize the use, function and performance of WealthPilot products and servicesWe may process personal information for WealthPilot’s own research and development purposes.For example: to enhance data quality, develop new features and functionality, and for statistical analyses related to the performance and operation of WealthPilot Advertising services.

c) to manage the security of our sites, networks and systemsWe can collect usage and systems operations data from WealthPilot Advertising services for security and operations management to help keep WealthPilot, customer, and partner networks and systems, as well as our products and services, secure. We may also collect usage and systems operations data to investigate and prevent cyber-attacks, malicious activity, or potential fraud, including ad fraud and to detect bots.

d) to comply with applicable laws and regulations and to operate our businessIn some cases, we may process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the operation of our business. For example, to conduct audits and investigations, for finance and accounting, archiving, and insurance purposes.

6. CATEGORIES OF SOURCES OF PERSONAL INFORMATION

WealthPilot may process both offline and online information about you, including information from publicly available sources or third-party data providers.

Offline information (for individuals located in the United States only) about you is obtained by WealthPilot from its offline partners such as consumer survey programs, and third parties who may not have a relationship with you and collect offline information from their offline partners.
Online information about you originates from your activities on sites operated by our online partners, such as advertising agencies and website operators (for example, online sites). WealthPilot also obtains online information from third parties who may not have a direct relationship with you and who collect online information using cookies or similar technologies, such as pixels tags and device identifiers, as you browse the Internet and interact with websites.
Device identifiers associated with your device originate from your interaction with applications, connected devices, or streaming devices. These identifiers are not collected in real-time and are sent periodically to OA by data providers in an offline file.

7. FOR WHAT PERIOD DO WE RETAIN INFORMATION ABOUT YOU?

WealthPilot maintains information about you for the following retention periods, unless retained solely for legal and compliance purposes:

Online information about you is retained for up to 13 months.Certain online information may be retained up to 18 months. For example, WealthPilot customers’ seasonal or cyclical interest-based advertising campaigns or internal analytics and model development may be retained for up to 18 months.
Online information about you for linkage purposes (cross device/cross-context technology) is retained for up to 12 months.
Offline information about you may be retained for as long as relevant for the purposes for which it was collected (see Section 5 above).

Personal information necessary to preserve opt-out preferences is retained for 20 years, unless you delete it or otherwise prevent its collection.

8. WHEN AND HOW CAN WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?

Sharing within WealthPilot

Information about you can be shared throughout WealthPilot’s organization for a business purpose(s). WealthPilot employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Disclosing personal information to third parties

We may share personal information with or sell personal information to the following third parties for a commercial purpose:

WealthPilot Advertising customers and partners, including digital marketers, ad agencies, web publishers, connected TV providers, demand side platforms, data management platforms, supply-side platforms, and social media networks; and
third-party service providers as necessary to perform WealthPilot Advertising services on behalf of WealthPilot.

We may disclose personal information with the following third parties for a business purpose:

relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings; and
public and government authorities, including public and government authorities outside your country of residence (to the extent legally required to respond to their mandatory requests in connection with national security and/or law enforcement purposes).

When third parties are given access to personal information, we will take appropriate contractual, technical, and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy and in accordance with applicable law.

9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

Personal information is processed as necessary in accordance with this policy. If personal information is transferred to an WealthPilot recipient in a country that does not provide an adequate level of protection for personal information, WealthPilot will take adequate measures designed to protect the personal information, such as ensuring that such transfers are subject to the terms of the adequate transfer mechanism as required under relevant data protection laws. Additional country-specific information on data transfers may be provided if you sign up for an WealthPilot SSO account (WealthPilot Account) or register for an event.

10. HOW IS INFORMATION ABOUT YOU SECURED?

WealthPilot has implemented appropriate technical, physical, and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as other forms of unlawful processing.

11. WHAT COOKIES, PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES DO WE USE?

Cookies and similar technologies (e.g., pixel tags and device identifiers) are used by WealthPilot and our advertising technology partners to recognize you and/or your device(s) on, off, and across different services and devices for the purposes specified in Section 5 above.

Cookies are small text files that contain a string of characters and uniquely identify a browser on a connected device. We or our WealthPilot Advertising partners may use cookies to, among other things, track user trends and collect information about how you use our customers’ sites or interact with advertising. Most browsers are initially configured to accept cookies by default. You may, however, be able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. Check your browser’s “help” files to learn more about handling cookies.

Pixel Tags are invisible 1 x 1 pixels that are placed on webpages that use this technology for marketing and measurement purposes. When you access these webpages, pixel tags generate a generic notice of the visit. Pixel tags can be used with cookies or alone. When used with cookies, pixel tags can track activity on a site by a particular device and provide relevant online advertising to you. When you turn off cookies or have opted out of cookies, pixel tags simply detect a unique website visit and how you interacted with the advertising, but do not track an individual to provide relevant online advertising.

Device identifiers are not collected via the technologies noted above but collected by application developers or third-party companies closely associated with the application developers when you download, register, or use these devices. The application must ask the device for permission to retrieve the device identifier on mobile devices. Such permission can be denied or revoked in your device settings.

You can opt out of these technologies using the opt-out tools in the next section.

12. WHAT ARE YOUR PRIVACY RIGHTS?

Pursuant to the applicable laws and regulations, individuals in certain jurisdictions may have data subject rights enabling them to request to opt-out of third-party sharing or selling, delete or correct, or request to access and receive a copy of their personal information in WealthPilot’s possession or for which WealthPilot is otherwise responsible.

Opt-out and object to our use of information about you

WealthPilot offers multiple ways for you to opt out of third party sharing or selling and object to our use of information about you:

WealthPilot Advertising Opt-out. Please note that if you use this opt-out, WealthPilot will opt you out of WealthPilot’s use of information about you for WealthPilot Advertising services involving both first-party use of your information as well as any third-party sharing or selling of your information. Customers remain responsible for their own first-party data collection and processing practices. See Section 2 above for more information on the distinction between first-party and third-party information.The WealthPilot Advertising opt-out will prevent WealthPilot from delivering third-party audiences to connected devices such as smart televisions or streaming devices; however, you can also visit your device’s settings menu or privacy policy for information on how to opt-out directly with your connected devices.
Do Not Track. WealthPilot honors “Do Not Track” browser settings, meaning we will not track your browser for marketing purposes while you have “Do Not Track” turned on in your browser settings.

Please note that if you opt-out using any of the opt-out options, you may still temporarily see interest-based advertising from WealthPilot Advertising customers due to advertising campaigns from those customers already underway. However, you will be opted-out of all future advertising campaigns from customers that use WealthPilot Advertising services.

Delete or correct information about you

Unless retained solely for legal and compliance purposes, WealthPilot will delete or correct your online or offline personal information, upon request, as set forth below:

You can erase or delete all online information about you by opting out of WealthPilot Advertising services.

Given the nature and purpose of the processing activities, in the event your personal information contains any inaccuracies, WealthPilot will delete your personal information per the process set above for deletion.

13. DOES WEALTHPILOT ADVERTISING COLLECT SENSITIVE PERSONAL INFORMATION?

WealthPilot does not create any online interest segments that reflect personal information that is sensitive, as defined by law and self-regulatory frameworks, or personal information that WealthPilot has deemed “sensitive.” We also have operational procedures in our platform designed to prevent our partners and customers from using personal information provided to them by WealthPilot to create interest segments that we consider sensitive. While the types of personal information considered sensitive may vary among consumers and applicable law, we treat the following types of personal information as sensitive:

precise mental or physical health, biometric, or genetic information, such as a certain sensitive medical condition like cancer or diabetes;
pregnancy, such as pregnancy choices, pregnancy termination, reproductive rights, and traveling to exercise reproductive rights;
certain aspects linked to personal life, such as racial or ethnic, religious, political, citizenship, immigration status, or sexual orientation;
social security or other state identification number, financial account numbers or login information for such accounts;
interest in “adult” activities, such as drug use, an interest in weapons, or pornographic material; and
information considered sensitive based on applicable law.

We do not allow WealthPilot Advertising customers or partners to use data provided to them by WealthPilot: (i) to make decisions related to an individual’s eligibility for employment, credit, healthcare, insurance, tenancy, or education purposes; (ii) to make decisions solely by automatic means where the decision has a significant effect on the individual; or (iii) in any way that may or does discriminate against any person or promote bigotry, racism, or harm. For these purposes, WealthPilot considers harm to be inclusive of the use of data provided by WealthPilot to target vulnerable individuals or groups with fraudulent or deceptive marketing campaigns or to be used in any manner that causes vulnerable individuals harm.

As noted above, WealthPilot Advertising does not create interest segments that reflect sensitive medical conditions.

14. DOES WEALTHPILOT ADVERTISING COLLECT PERSONAL INFORMATION FROM CHILDREN?

We do not intentionally collect or share personal information of children under 16 years of age or allow the creation of segments targeting children under 16 years of age. Further, we prohibit our WealthPilot Advertising partners from providing WealthPilot with personal information from sites directed to

15. DATA PROTECTION OFFICER

WealthPilot has appointed a Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, please contact the Data Protection Officer by submitting an enquiry to us.

16. FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law. You also have the right to file a complaint with a competent data protection authority.

17. WEALTHPILOT CORPORATE HEADQUARTERS

WealthPilot’s corporate headquarters are located at:

105/838 Collins Street

Docklands, Victoria, 3008

Australia

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