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Zync Compliance Requirements

Privacy Policy

The Brand is required to provide notice to consumers in its website privacy policy about the data practices associated with the Zync re-targeted email product. Specifically notice that:

  1. Cookies are automatically dropped or recognized on the consumer’s device when they visit the website;
  2. Cookies and other tracking technologies automatically collect non-personally identifying information about the consumer’s visit to the webpage, including, but not limited to, the consumer’s device ID, browser type, IP address, pages visited, and information associated with such non-personally identifiable information, such as browsing history;
  3. Such non-personally identifying information may be shared with third party service providers who may combine such information with personally identifying information, such as an email address, for the purpose of sending the consumer marketing messages targeted or personalized based on the consumer’s online activity and browsing history, including by email (“Retargeted Marketing”); and
  4. A conspicuous link to an opt-out mechanism that allows the consumer to opt-out from third party cookies (http://www.aboutads.info/choices) and from use of their mobile device ID for some interest based advertising (http://www.aboutads.info/appchoices).

Sample Privacy Policy Language

“The information that we collect about you may be used by us or by third parties we engage in any manner and for any purpose permitted by law. This may include combining your personally identifiable information, such as your email address, with information that does not identify you personally, such as your IP address, device ID, a unique cookie placed or recognized on your browser, or information associated with such non-personally identifiable information, such as information about your browsing history, whether collected on this site or a third-party site. We, or third parties we engage, may use this combined information to send you relevant marketing, including by email, about our products or services or the products or services of third parties. To Opt-Out from these services, please go to (http://www.aboutads.info/choices) opt-out from third party cookies, http://www.aboutads.info/appchoices to opt-out from use of their mobile device ID for some interest based advertising.”

Unavoidable (“Just in Time”) Notice

The Brand is required to include a pop-up banner on their website that notifies the consumer about the use of cookies on the Brand’s website, and that such cookies are used to identify the consumer for marketing. The Just In Time Notice must appear in the form of a banner ad, similar to a cookie notice required by the European Commission, include a link to the Brand’s privacy policy and bear language substantially similar to the language provided below.

Sample Unavoidable (“Just In Time”) Notice:

“We use cookies on our website to ensure you have the best experience and to send you relevant marketing. By closing this banner or interacting with our site, you permit us and our partners to place cookies on your browser, recognize cookies, and identify you for marketing. [Link to Brand’s Website privacy policy]”.