PRIVACY POLICY

EL TORO Data Services and Website Privacy Policy

Last Modified:  April 2, 2020

EL TORO.COM LLC doing business as EL TORO (“EL TORO,” “We,” or “Our”) helps our clients, who are generally marketers, advertisers and their agencies and providers (collectively “Clients”) to tailor their advertising to consumers who are most likely to consider their ads relevant, based on those consumers’ activities, interests, and demographics.  We work with Clients across various marketing methods and channels, including display media, email, and direct mail, and perform data services and analytics, including the services described on our website.  

EL TORO is a strong supporter of individual privacy and a protector of personally identifiable information.  EL TORO adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles, which is a prominent industry standard setting forth guidance for consumer privacy protection.

The following constitutes EL TORO’s Privacy Policy (“Privacy Policy”) and is intended to provide a transparent look into EL TORO’s data practices.  You may click here to learn more about how to opt-out of EL TORO’s services.  If you are a California resident (as defined by the California Consumer Privacy Act of 2018), please see our California Privacy Policy Rights Addendum here, which supplements the information in this Privacy Policy for California residents.  California residents may also opt out of the “sale” of their personal information by clicking here, or may request access to or deletion of their personal information by clicking here.

The Types of Information We Obtain and Use To Provide Our Services
EL TORO may receive or collect the following types of information (collectively, the “Information”) from a variety of consumer-facing companies and services, data compilers and suppliers, publicly available data (such as from government and public sources), and marketing platforms (collectively, “Marketing Platforms”) as well as from Clients when we perform services for those Clients:

  • Personal Identifiers (“PI”), such as first and last name, alias, postal address, IP address, mobile ad identifiers, and email and corporate addresses; 
  • Demographic information, such as general descriptive information on age, occupation, education, gender, etc., associated with an individual or household.  
  • Commercial or transactional information, such as records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies;
  • Professional or employment-related information, such as categories of occupations (generally inferred) or job titles of potential business prospects;
  • De-identified information related to unique user behavior, such as browsing history, or online interests, like the fact that a particular user tends to visit sports websites or entertainment websites;
  • Geolocation data based on mobile ad identifiers;  
  • Unique individual identifiers that we, our Clients or other companies (such as ad and data companies) may create in order to identify a unique, de-identified user’s device or browser.  We may use cookies and similar technologies that are linked to these identifiers (see Section 7); and 
  • Hashed values that are derived from PI (such as email addresses) but have been de-identified, through various means. 

As set forth below in Section 6, we also collect certain Information on our website, that you may provide to us, or that we may collect passively.  We may combine, link, or aggregate certain elements of the above information with each other.  

We also may receive information from our Clients, to whom we act as a service provider.  That information may include Clients’ customer names, addresses, and other information about those relationships.  That information is more fully described in the privacy policies of each of our Clients. 

How We Use the Information
We may (but do not necessarily, or always) use PI and other Information we hold or collect to provide a number of marketing-related services, through online display, email, and/or direct mail marketing channels.  A non-exhaustive list of our services is as follows:

  • Targeting of Ads and Content. We provide services that help marketers target display media to their own customers or to their likely customers safely and effectively, through various media and advertising channels.  For instance, we use the Information to provide services to enable Clients to target “multi-channel” ads to their own customers, prospective customers, or consumers that have visited or logged in to their websites.  In doing so, we often employ various de-identification and data segregation techniques to safeguard consumer privacy. We also may use or create “Audience Segments” that help us or others (e.g., brands) tailor ads and content based on a particular user’s preferences, such as an interest in sports, travel or entertainment.
  • Optimization of Ad Campaigns.  We help our Clients optimize their advertising campaigns – for instance, by limiting the frequency or adjusting the sequence of advertising shown to customers.  We also may use the Information to customize ads to a particular geographic region, or to the content of a web page on which they are shown.
  • Campaign Measurement.  We measure the effectiveness of display media campaigns – for instance, to determine which types of ads are most likely to be seen or opened, in what circumstances, or by which types of customers, or which types of ads are most likely to lead to clicks, purchases, or other behavior.
  • Other Data Services.  We sometimes use PI and other Information to provide other data services, such as (but not limited to) email and direct mail marketing services, as well as analytics services to help marketers optimize marketing to prospects.
  • Improving Our Own Services.  We may use certain PI and other Information to improve, analyze, and develop our own services.

The above descriptions of our services are not exhaustive.  We provide them to illustrate in a general way the services we offer, and how PI and other Information is used.  

How We Work and Share Information with Third Parties
EL TORO may share Information with Clients, Marketing Platforms, and service providers that we work with or retain, in order to provide the services described above (or other services we may add).  More specifically:

  • Partners:  We may share Information with business and data partners (including Marketing Platforms) to deliver ads, to help provide more tailored advertising, and for analytical purposes, such as to measure campaigns, to inform future campaigns, or to handle, analyze, or segregate the PI and other data that we handle for Clients.  We may also share Information with our service providers, such as providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or service providers otherwise assisting us to provide, develop, maintain and improve our services.
  • Corporate transfers:  If EL TORO or its significant assets are purchased by another entity, our Information will be transferred to that entity.  We also may share the Information during the course of any due diligence process or preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation.
  • Affiliates, Parents and Subsidiaries:  EL TORO may share some or all of the Information in our possession with affiliated or subsidiary companies. 
  • As Required by Law or to Protect Any Party:  EL TORO may disclose Information if we believe that such disclosure is necessary (a) to comply with relevant laws or legal processes, such as to respond to subpoenas or warrants served on us; (b) to enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) to respond to claims that any content violates the rights of third parties; and/or (d) to protect or otherwise defend the rights, property, or safety of EL TORO, our platform, our clients, our agents and affiliates, and/or the public.  We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, spam/malware prevention, and similar purposes.

Your Opt-Out Rights
You may opt out of the EL TORO marketing platform database by accessing our opt out page.  California residents may use this same page to opt out of the "sale" of their personal information, pursuant to the California Consumer Privacy Act.

You may opt out of receiving advertising from the online Marketing Platforms that we partner with, and learn more about companies that engage in various types of online targeted and retargeted advertising, by visiting the opt-out pages offered by the Network Advertising Initiative (NAI) (here) and the DAA (here).  Opting out in this manner will not prevent you from seeing ads; it will prevent targeted ads customized to what these companies believe are most likely to be relevant and of interest to you.  In addition, opting out in this way is browser-specific, so if you change your browser, update it, or clear your cookie cache, you will need to opt out again.

  • We and Others May Use Cookies, Pixels and Similar Technologies
    EL TORO uses industry-standard technologies, including cookies and similarly functional technologies.  Cookies are small data files made up of a string of characters, such as an anonymous unique browser identifier.  Cookies are stored on your computer or other device and act as unique tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website.  A pixel tag (also known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access these web pages, pixel tags generate a generic notice of the visit and permit us to set or read our cookies.  Pixel tags are used in combination with cookies to “remember” the activity on a site by a particular device. When you adjust your browser settings to stop accepting cookies, pixel tags simply detect an anonymous website visit. We and other Marketing Platforms may use cookies to, among other things, retain the history of activity on a site, track user trends, and collect information about whether and how you use our Clients’ sites or interact with the advertising we deliver on their behalf.  We use cookies to help our Clients and other Marketing Platforms provide relevant content to you and replace non-relevant ads with ads that better match your interests.

While EL TORO cookies expire, we may retain purely aggregated versions of the Information (i.e., not tied to a cookie or device) indefinitely.  We may work with third parties to provide or enhance our services (e.g., for purposes of retargeting and tailoring ads, or placing browser cookies).  These parties may set and access their own cookies, pixel tags, and similar technologies on your device, which may have cookies with varying expiration periods.  Those parties may, likewise, collect various types of anonymous or de-identified information about your browser, device, or browsing activities through use of these cookies.  

Most web browsers are set up to accept cookies.  You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies.  However, if you disable the use of cookies in your web browser, some features or services may be difficult to use or inoperable.  In providing our services, we or other companies we may partner with may (but will not necessarily) work with certain third-party companies that use techniques other than cookies to recognize your computer or device and/or to collect and record information about your web browsing activity, including those integrated with our services.  These technologies may not respond to browser settings that block conventional cookies.  

Data Collected Through Our Website
We also collect data through the website(s) we operate, including any website on which this Privacy Policy is posted.

  • The information we collect from users of our website includes:
  • The domain name and IP addresses of users’ web browsers.
  • A unique identifier (such as in a cookie) that we deploy or read on your browser.
  • Aggregate information on what users access, utilize, or visit.
  • Information, including PI, that you voluntarily provide to us, such as requests for newsletters, events, and other information, and submission of contact information (such as email address) and (if you decide to provide it) credit card information.
  • EL TORO uses the information we collect from users of our website to:
  • Create and manage your unique user account.
  • Provide services to you.
  • Respond to and communicate with you (including regarding news and updates about our services).
  • Send you offers and ads for our services, when you browse the site or other sites on the Internet.
  • Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you.
  • Perform data analyses (including market research).
  • We may combine the Information with other information we obtain from third parties, publicly available sources, and any other service we provide to further improve the relevance and effectiveness of products, services, and advertisements offered, including, but not limited to, those provided on or through the services.
  • We may use IP addresses to help diagnose problems with our servers and to administer our site.  We also may use IP addresses to help identify visitors to our site for the duration of a session and to gather demographic information about our visitors. 
  • We may use clickstream data to determine how much time visitors spend on each web page of our site, how visitors navigate through the site, and how we may tailor our site to better meet the needs of our visitors. 
  • We also use the information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms of Service.

  • We may sometimes share, sell, or otherwise disclose the Information we collect about you through our website, as follows:
  • We may share the Information with service providers who help us deliver the services you request or we provide.
  • We may share the Information to communicate with you and market to you, including through email, direct mail, or display media.
  • We may also disclose the Information (including PI) in accordance with this Privacy Policy.

EL TORO’s website(s) uses cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet).  For more information about cookies and similar technologies, please go to the Section titled, "We and Others May Use Cookies, Pixels and Similar Technologies" above.

Links
EL TORO’s website(s) may provide links to other websites that EL TORO thinks users will find interesting or useful.  EL TORO is not responsible for the privacy practices of these other sites.

Security and Data Integrity
EL TORO takes various steps to protect the Information we license or maintain, and to house and transmit that Information in a secure way.  For instance, these steps may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information.  While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we take these steps in an effort to ensure this does not occur.

Children Under 16
EL TORO does not actively seek to collect the personal information of children under 16 years of age, and EL TORO’s website(s) and services are not intended for use by children.  If you have concerns about use of your child’s personal information, you may contact us at privacy@eltoro.com.     

Binding Agreement; Changes
We may revise this Privacy Policy at any time and with an associated effective date.  Any revised Privacy Policy will be posted on EL TORO’s website(s).

Questions or Concerns
If you have questions or concerns about EL TORO’s privacy efforts or data practices or services, please contact us at privacy@eltoro.com or by U.S. Mail to:

ATTN:  Privacy Officer
EL TORO
124 N. 1st Street
Louisville, KY 40202