Effective Date: May 25, 2018
Light Reaction is firmly committed to protecting user privacy and fostering user confidence in the Internet and digital advertising. We continually evaluate innovative ways to protect user privacy while also seeking to deliver relevant advertising and custom online experiences on behalf of our clients.
This Privacy Notice describes the information Light Reaction collects from web sites, applications, and other digital properties (we refer to all of these as "Sites"), and on the Light Reaction corporate web site, www.lightreaction.com ("Light Reaction Web Site"). We explain how we use this information to provide "Services" to our clients. We also explain how you can manage your privacy choices and exercise your rights in relation to certain data about you that is collected and used by Light Reaction. Please note that this Privacy Notice has been translated from English into multiple different languages. If there are any conflicts or inconsistencies between the different language versions of this Privacy Notice, the English version will prevail.
Light Reaction is part of the Xaxis programmatic media group; Xaxis is a business which operates globally as part of the GroupM media investment group; GroupM is part of the WPP plc group of companies. Through its Light Reaction division, the legal entity responsible for the data that Light Reaction collects is Quisma GmbH. For purposes of clarity and this Privacy Notice, Light Reaction's Services do not include the other services of Xaxis or Quisma. For information on how Xaxis collects and uses information through its other services (as opposed to the collection and use of information through Light Reaction's Services or on this website), please click here. For information on how Quisma collects and uses information through its other services (as opposed to the collection and use of information through Light Reaction's Services or on this website), please click here.
If you have any questions or comments regarding this Privacy Notice, please see the information beneath "Contact Us" in Section 3 of this Privacy Notice.
Light Reaction Services
Light Reaction does not provide its advertising-related services ("Services") directly to consumers. Instead, our clients are corporate businesses, including advertisers and agencies. Our clients include other GroupM and WPP group companies, which in turn perform advertising-related services for their own clients.
Our clients use our Services, on their own behalf and/or on behalf of their own clients, to help them understand the advertising that the clients deliver online (e.g. what sites it was delivered on, who saw it and whether or not anyone interacted with it) and to improve the effectiveness of that advertising and we also help them to try to deliver advertising to consumers who are more likely to be interested in their products and services.
When we help clients to select audiences to deliver their advertising to, we use certain demographic information (such as age, gender, education, income and household status (e.g., number of children)), geography, interests, activities, and similar information ("User Information"). We call this type of advertising "Interest-Based Advertising".
For example, if we think that a user is interested in mobile phone options, then our Services may help our clients deliver Interest-Based Advertisements to that user about a particular type of mobile phone product or service, as follows:
Types of Information We Collect and Use through Provision of Our Services
When you view and interact with Sites and with advertisements where our Services are utilized, our Services are designed to collect and/or use information about the type of web pages that individuals visit and about interactions that they have with Sites and with our clients' advertisements. We also collect information that identifies the browsers and devices of the individuals who have viewed our clients' advertising. This information includes the following categories of data:
These can be used to identify an individual's browser, mobile advertising environment, and/or device, and typically include:
- Cookie IDs
- Mobile advertising IDs (e.g., IDFAs and Google Advertising IDs)
- Our affiliate [m]PLATFORM's "[mP]ID" proxy identifier for the above IDs
Additional Technical Information
- Internet protocol address ("IP address") and data derived from an IP address, such as non-precise geolocation data that indicates the country, region, city, and/or postal code of a device
- Type of Internet browser, browser language, and operating system
- Connection type (wired or Wi-Fi), network to which the device is connected, and mobile carrier (if available)
- Longitude/latitude of a (mobile) device
For purposes of this Privacy Notice, "device" includes computers, smartphones, tablet computers, e-readers, and other digital devices capable of maintaining an Internet connection, and "mobile device" includes smartphones and tablet computers.
Online Activity Information
Light Reaction collects the information explained below about your online browsing activity to determine what types of activities, services and products you and other users may be interested in and how you and other users interact with certain advertisements. This information includes: - Records of the types of Sites and pages viewed (i.e., in order to ascertain interests)
- Site/page you came from before, and visited after, viewing an advertisement
- Date and time of online activity
- Frequency of visits to a Site
- Search terms used on a Site
- Interaction with an advertisement (e.g., whether a user clicks on an advertisement)
User Information received from Third Parties
We also receive both online and offline User Information collected by third parties, including demographic and interest information for use in our Services. The third parties include our clients and carefully selected service providers. When we receive offline User Information, this information is provided to us via a service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a customer or consumer to us, the client or service provider, but we do not receive users' names, mailing addresses, phone numbers, email addresses or similar data that would enable identification of a particular individual connected with these IDs.
How We Collect Information through Our Services
The following chart provides information about the Mookie cookies, all of which are "persistent" cookies (meaning they are stored until they expire or are deleted/removed by a user) mapped to the mookie1.com domain:
How We Use This Information
Light Reaction processes the information it collects and receives for the purposes of providing the Services to clients which we have explained above, as well as for administrative, security and compliance purposes. Specifically, we carry out the following activities:
Ad Selection, Delivery, Reporting
We analyze the information collected when client advertising is delivered using our Services and information received from our partners. We organize this information into collections of IDs (which we call segments), based on various components of the User Information we explained above. For example, we may have segments of IDs that visit sports Sites. Our clients can then use our Services to use these segments to deliver Interest-Based Advertising on their own behalf or on behalf of their clients, using our partners and service providers. This advertising may be delivered across computers, smartphones, and other devices.
We may also integrate (and use for the same purposes) User Information obtained from other carefully selected companies (including Site owners, data providers and data aggregators).
We also make use of the internal identifier of our affiliate [m]PLATFORM, called "[mP]ID". We use the [mP]ID to associate information relating to browsers, environments and/or devices that we, or [m]PLATFORM, reasonably believe belong to the same user. This helps us to provide more useful and relevant advertising to a specific user, regardless of the browser, environment or device.
In order to provide our client-specific personalization Services, we:
- collect information on each client's Sites (this includes websites, apps, and other digital properties) — as described above in "How We Collect Information through Our Services";
- access or store this information on devices (via cookie IDs and advertising IDs, as applicable); and
- analyze the information collected, sometimes with other information received from the client and organize it into segments of IDs, based on the various User Information.
Our clients can then use these segments to deliver, on their own behalf or on behalf of their clients, Interest-Based Advertising to users on their computers, phones, and other mobile devices (this is through a variety of means).
Where we are providing this client-specific personalization, the segments that we build for one client are logically segregated from the segments and data of other clients. Data collected in this way, and the segments produced, can only be used on behalf of the specific client.
We process User Information to deliver advertisements and measure the delivery of these advertisements, to learn about what factors make advertising successful or unsuccessful for advertisers, and to generate reports to understand and improve Service usage and advertising effectiveness.
Storage and Access of Information
In order to provide our Services, we store Mookie cookies on the browser(s) of individuals to whom we have delivered advertising and then recognize the Mookie cookies when that browser(s) is used to access websites of our clients and publishers we work with. Sites on which we are dropping and/or reading Mookie cookies (or seek to drop and/or read Mookie cookies) should tell you about the use of third-party cookies (and, in particular, Mookie cookies specifically, where required by law), on those Sites. In the data feeds we receive from our partners in connection with the delivery of digital advertising in mobile application environments we also receive advertising IDs associated with users' mobile device platforms/operating systems and recognize these advertising IDs.
We use the information collected and received for Interest-Based Advertising, such as:
- Matching Data to Offline Sources — as indicated above under "User Information received from third parties":
• We receive offline User Information, including demographic and interest information, from other companies, including our clients, partners and service providers, that is collected outside the Services and is provided to us for use in our Services. It is the responsibility of those companies collecting that data to do so in an appropriate and legal way, and to permit sharing that information with us for our purposes.
• When we receive offline User Information, this information is provided to us via a service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a customer or consumer to the client or service provider.
• We do not receive any names, mailing addresses, phone numbers, email addresses or similar data that would enable identification of a particular individual connected with the IDs we receive.
- Linking Devices — we make use of the internal [mP]ID identifier of our affiliate [m]PLATFORM to associate information relating to browsers, environments, and/or devices that [m]PLATFORM or we, reasonably believe belong to the same user, in order to help provide more useful and relevant advertising regardless of browser, environment, or device.
- Precise Geographic Location Data — when we have the necessary rights to do so, we may receive and/or use a user's precise geographic location data in connection with our Services. Where we collect this type of data it is provided in the data feed we receive from our partners in connection with the delivery of digital advertising.
Disclosure of Information to Third Parties
Our affiliate [m]PLATFORM operates and maintains a proprietary data management platform that we and other affiliates may use in order to provide services. The information we disclose to [m]PLATFORM may be used by mPlatform and such other affiliates not only to provide services to us and our clients, but also to provide services to those affiliates and their respective clients.
We may also disclose the information we collect to third parties, including law enforcement, when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.
Opt-Out/Right to Withdraw Consent
You may opt out of Light Reaction Interest-Based Advertising through several mechanisms.
You may choose not to receive customized third-party advertisements via Mookie targeting cookies (which are used by both Light Reaction and Xaxis) on the browser you are using by clicking below. If you do this, your third-party Mookie targeting cookie will be replaced with an "opt-out" cookie, and any Interest-Based Advertising data linked to the replaced third-party Mookie targeting cookie will not be used for Interest-Based Advertising on any device or browser that we have reasonably linked to the browser where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to the opted-out browser, that other device or browser will also be opted out from receiving Interest-Based Advertising via Light Reaction.
Our opt-out cookies are programmed to expire ten years after they are initially issued. If you buy a new device, upgrade or change web browsers or delete this opt-out cookie, you will need to perform the opt-out process again. In order for the opt-out process to work, your browser must be set to accept third-party cookies.
In browser environments, you may also refuse or remove cookies from both Light Reaction and other service providers via the following methods:
- Adjusting your browser settings to refuse or remove cookies, which would result in the elimination of Interest-Based Advertising via cookies from Light Reaction and from other providers in addition to Light Reaction. However, by doing so, you may not be able to use certain features on certain web sites you visit or take full advantage of all web site offerings and Interest-Based Advertising. You may refuse or remove cookies by following the directions provided in your browser settings. Further information about cookies is available at www.aboutcookies.org, www.youronlinechoices.com and http://www.aboutads.info/consumers#cookies.
-Adjusting the cookie settings at the level of the web site owner where you granted us your consent to our cookie usage; cookie settings options may vary by web site owner.
- Opting out of Interest-Based Advertising by Light Reaction via Mookie targeting cookies, as well as the targeting cookies of other service providers, at www.youronlinechoices.com (by clicking the "Your ad choices" link after selecting your country); or opting out of Interest-Based Advertising by Xaxis via Mookie targeting cookies, as well as the targeting cookies of other service providers, at the following Sites:
In mobile app environments, you may opt out of Interest-Based Advertising from just Light Reaction or from both Light Reaction and other service providers by going to the privacy setting on your device and selecting "Limit Ad Tracking" via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from Light Reaction and from other providers in addition to Light Reaction.
Additional information regarding user choice in application environments is available at www.networkadvertising.org/mobile-choices; for purposes of clarity, Light Reaction is not a member of the Network Advertising Initiative.
European Interactive Digital Advertising Alliance
We are a member of the European Interactive Digital Advertising Alliance (EDAA) and, in connection with this membership, adhere to the IAB Europe EU Framework for Online Behavioural Advertising in those markets where this self-regulatory framework applies.
Light Reaction supports deployment of the "AdChoices" Advertising Option icon as part of its participation in the IAB Europe OBA Framework for Online Behavioral Advertising (in Europe). Advertisements that are provided by organizations that participate in this framework will display the icon displayed below when technologically feasible. Clicking on the icon provides you with information about Interest-Based Advertising.
You can click here to reach the EDAA site, which has additional information about Interest-Based Advertising (or "Online Behavioural Advertising") and the EDAA's self-regulatory framework, as well as a mechanism to opt out of receiving third-party Interest-Based Advertising via cookies from us and other EDAA member companies.
Neither the Services nor the Light Reaction Web Site is developed for, or directed at, children (as defined by applicable law) or at Sites primarily directed to children. We do not knowingly collect information from children (determined in accordance with the age requirements for the applicable country). If you believe a child has provided us with personal data and you would like to have the information removed, please contact us.
Transfer of Data in the Event of Acquisition
In the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information (including any information a user may have provided through our "Contact"/"Contact Us" page on the Light Reaction Web Site) that is in our possession or under our control to the acquiring party.
Information Security and Global Data Transfers
We follow generally accepted online advertising industry standards to protect against unauthorized access to, unlawful processing of, unauthorized retention of, and unauthorized disclosure of data. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure.
Light Reaction Services are used globally, and therefore we may transfer data to countries around the world, including countries outside of your country. We will, where necessary, put in place appropriate safeguards to ensure this data is protected. When we transfer personal data from the EEA or Switzerland to an affiliate outside the EEA or Switzerland, we enter into standard ("model") contractual clauses, with the recipient in order to ensure an appropriate level of data protection. When we transfer personal data from the EEA or Switzerland to an unaffiliated entity (such as a service provider performing services on our behalf) outside the EEA or Switzerland, we either enter into standard ("model") contractual clauses, or substantially equivalent terms and conditions, or ensure that the transfer is pursuant to another valid mechanism, such as the service provider being certified under the EU-U.S. Privacy Shield Framework.
We maintain the information we collect through our Services in non-aggregated form for a period of not more than 13 months. This data includes Sites visited, content viewed, ad interactions, IP addresses, browser type and language settings. We maintain this information for the 13-month period to enable our clients to perform year-over-year analyses. For example, a retailer may wish to compare the effectiveness of its online advertising activities at Christmas for the current year vs. the effectiveness in the prior year. A 13-month retention period enables that client to perform such comparison.
We maintain information we collect through our Services in an aggregated form for a period longer than 13 months.
How Information is Used and Shared on the Light Reaction Web Site
We respect the privacy of users of the Light Reaction Web Site, and recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner with that information. This section contains important information about how we use information collected via the Light Reaction Web Site and how you can manage your privacy choices and exercise your rights in relation to certain data about you that is collected via the Light Reaction Web Site.
What Information Do We Collect and Use, and How Do We Use It?
When you use the Light Reaction Web Site, we may collect and use technical identifiers that can be used to identify an individual's browser, mobile advertising environment, and/or device, which may include IP address and/or cookie IDs. We use this information to improve the content, speed, and security of the Light Reaction Web Site.
Do We Pass Your Information to Third Parties?
We may send your information (including your personal data) to our affiliate GroupM, service providers and other third parties to help us process that information for the purposes set out in this Section 2 of this Privacy Notice. In addition, in the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, purchase, or other transaction, we reserve the right to transfer your information (including your personal data) to the acquiring party.
We also may disclose your information (including your personal data) to third parties, including law enforcement, when we reasonably believe we are required to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.
Where Do We Send Your Information?
We are a global company and therefore we may transfer your information (including your personal data) to countries around the world, including countries outside of your country. We will, where necessary, put in place appropriate safeguards to ensure your information is protected. When we transfer personal data from the EEA or Switzerland to an affiliate outside the EEA or Switzerland, we enter into standard ("model") contractual clauses with the recipient in order to ensure an appropriate level of data protection. When we transfer personal data from the EEA or Switzerland to an unaffiliated entity (such as a service provider performing services on our behalf) outside the EEA or Switzerland, we either enter into standard ("model") contractual clauses, or substantially equivalent terms and conditions, or ensure that the transfer is pursuant to another valid mechanism, such as the service provider being certified under the EU-U.S. Privacy Shield Framework.
How Do We Keep and Protect Your Information?
We will keep your information that we collect on the Light Reaction Web Site for a reasonable period for the purposes set out above in this Section 2. We follow generally accepted online advertising industry standards to ensure that your personal data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure.
Linking to Other Sites
For information on how to opt out from, or manage, Light Reaction cookies and/or cookies from both Light Reaction and other service providers, please see the "Opt-Out/Right to Withdraw Consent" subsection in Section 1 above.
The Light Reaction Web Site is not intended or designed to attract children (as defined by applicable law). We do not knowingly collect personal data from children (determined in accordance with the age requirement for the applicable country). If you are a child and wish to ask a question or use this site in any way which requires you to submit your personal data, please get your parent or guardian to do so on your behalf.
EEA and Switzerland
Legal Bases for Processing Information
We collect, use, share, and/or transfer personal data of individuals in the EEA and Switzerland only when we have a lawful basis for doing so, which typically entails user consent or our legitimate interests.
Where required by applicable law we only deliver Interest-Based Advertising to individuals who have provided consent for that activity.
To the extent we rely on your consent, which may be provided either directly to us or via a third party, to use your information in certain ways, we will process your personal data within the scope of that consent.
In our capacity as a data controller we intend to rely on consent as a lawful basis for all "Purposes" under the IAB Europe's Transparency & Consent Framework other than "Measurement" (which Purpose includes measurement, analysis, and reporting with respect to the applicable personal data). In connection with such Purpose, when we process data for measuring the delivery of advertising or analyzing its effectiveness we have a legitimate interest in understanding that our suppliers have delivered the advertising that they have contracted to deliver. In addition, we believe that advertising clients have a legitimate interest in understanding whether or not their advertising is delivered and whether it is effective. We believe these activities are fundamental to online advertising but do not result in any decisions which affect individuals.
If you are in the European Union, you have the right to object to any of this processing. If you want to object, please click here.
Rights of Individuals in the EEA and Switzerland
Individuals in the EEA and Switzerland have a number of rights with regard to their personal data, including the right to access their information. For these users, in many cases where we process your personal data, you may also have a right to restrict or limit the ways in which we use that personal data.
In certain circumstances - for example, where we process your personal data for directing marketing purposes or pursuant to our legitimate interests - you also have the right to object to the processing of your personal data by us, and you can also request that we delete your personal data. You also have a right to obtain a copy of your personal data in an easily accessible format, and in certain circumstances, you may also request us to transfer personal data about you to third parties. We don't retain and store your actual browsing activity history in association with a Mookie cookie ID or a mobile advertising ID. Instead, we use an "aggregate scoring" methodology that categorizes the Sites you browse and then use combinations of these categorizations to create segments and deliver Interest-Based Advertising. As a consequence, we are unable technically to offer the ability for you to change individual elements of data that lead to the segment allocation simply because we do not retain them. If you believe that we hold or have used inaccurate personal data elements about you, please note that you have the right to withdraw your consent to our processing of your personal data at any time.
If you have questions about any of these rights, please contact us. You should also contact us if your personal data or preferences change, if you don't want us to send you the information you previously requested, or if you have any queries about how we use your personal data.
Without limiting any other rights you may have, you also have the right to lodge a complaint against us with a supervisory authority in the EU Member State where you are based or in which we are based. Click here to find your local supervisory authority.
Information Received from Market Research Companies in the Netherlands
If you have provided consent to market research companies in the Netherlands to disclose your panel data to Light Reaction, then, based on the scope of such consent: we may receive User Information and other information, including panel IDs, from such companies; and we may use this information only for purposes of research and analysis, campaign optimization, advertising customization, and reporting on the effectiveness of online advertising campaigns.
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of "personal information" that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of companies, if any, to which Light Reaction has provided personal information for its own marketing purposes, please contact us through email at email@example.com or by mail at Light Reaction, c/o Xaxis, 140 East 45th Street, 12th Floor, New York, NY 10017, USA, Attn: Legal Department. Please allow 30 days for a response.
California law requires us to disclose how we respond to browser "Do Not Track" signals or other choice mechanisms relating to Interest-Based Advertising. We have not yet developed a response to browser "Do Not Track" signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to "Do Not Track" signals in light of industry developments or legal changes.
We are committed to honoring your privacy choices. For more information on opting-out of Interest-Based Advertising, please see the "Opt-Out/Right to Withdraw Consent" subsection of Section 1 above.
Changes to this Privacy Notice
Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).
Other than when acting at the direction of a client or other third party, Light Reaction is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you interact with our Services.