Privacy Policy

Effective April 07, 2021

TrackingHub, operated by TOGIZU TECHNOLOGIES Ltd. (“TrackingHub”, “we”, “us”, “our”) provides a partner marketing platform. This Privacy Policy is provided to help you understand how TrackingHub processes (i) end user data on behalf of our clients who use the TrackingHub partner marketing platform, and (ii) your data when you visit TrackingHub’s corporate family of websites, including trackinghub.net (the “Websites”). It does not state the use practices or policies of our clients, of the websites or apps on which ads are shown, or of other parties.

TrackingHub cares about how end user data is collected, used, and shared. We are a “data processor” that collects and analyzes end user data at the specific request of our clients, the “data controllers”.

TrackingHub Platform and Data Pledge

TrackingHub is the partner marketing platform, used by the world’s top mobile and desktop advertisers and networks to measure and manage their online advertising relationships. Clients use TrackingHub to assess the effectiveness of their partner relationships and act on those results.

Pursuant to the TrackingHub Data Pledge, our clients determine the data that they provide to and collect through TrackingHub. Clients’ use, collection, exportation, or any other use of end user data is governed by their own privacy policies and applicable laws, rules, or regulations.

What Information Does TrackingHub Collect From Clients?

At the direction of our clients, who act as data controllers, TrackingHub collects the following types of information from end users to help clients measure and manage their marketing partner relationships:

• Ad Identifiers (unique character strings associated with user devices that help monitor and measure user interactions with advertisements and apps, such as Apple’s IDFA and Google Ad ID; Ad Identifiers may be reset by the user)
• IP address
• Cookies
• Pixel tags
• Imprecise geographic location data derived from IP address and/or wifi networks

Our clients may also choose to share certain account information for both clients and their partners on the TrackingHub Platform. This may include corporate and employee information necessary to maintain the services and up-to-date contact information, including: name, mailing and/or billing address, email address, company name, website url, user name, password, and phone number. Clients using TrackingHub to manage payouts to their partners may also choose to share certain banking information as necessary to carry out the services.

Clients can also choose to view and measure information provided by other third-party sources in the TrackingHub Platform. Those sources may include advertisers, publishers, marketing partners, and other advertising networks and analytics partners. Marketing partners may sign up with advertisers through the TrackingHub Platform or through their own customer website. Marketing partner information provided to our advertiser clients may be used by TrackingHub for fraud prevention purposes and to fulfill contractual requirements with advertisers.

Clients own the data that they provide to and collect through the TrackingHub Platform. When clients remove or export their data from the TrackingHub Platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations. TrackingHub serves as a data processor, acting at the direction of our data controller clients. Specific fields that likely contain personal data, such as IP address or device ID, may be obfuscated or blanked, respectively, by the TrackingHub client.

What Information Does TrackingHub Collect On the Websites From End Users?

When you visit the Websites, TrackingHub collects information about your device and use of the Websites to understand how to improve its Websites. TrackingHub also collects any information you voluntarily provide when you visit the Websites to learn more about TrackingHub and its products, sign up for TrackingHub services, or apply for employment at TrackingHub . The type of information collected will depend on your request and interaction with the Websites. Categories of information may include specific times of day you accessed the Websites, the IP address of the device you used to access the Websites, the pages on the Websites that you viewed, the pages you visited before navigating to the Website(s), and information about the device you use to access the Websites, including hardware model, operating system and version, and browser.

TrackingHub uses the information collected on the Websites for various purposes, including:

• Ensuring its Websites remain relevant to end user needs and are easy to use by providing analytics and other data regarding use of our Websites.
• Sending marketing and promotional communications in compliance with applicable laws.
• Enhancing, improving, or modifying its Websites and services, enhancing security, or combating spam or malware or other security risks.
• Providing confirmations, invoices, technical notices, updates, security alerts, and other support and administrative messages.

How Do Clients Use TrackingHub To Collect Information From Users?

Clients may use TrackingHub for server postback tracking to collect certain performance marketing information about end users. In postback tracking (also called “server-side tracking”), TrackingHub directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to TrackingHub for validation.

TrackingHub also supports server-to-server measurement for some clients. With any of the mentioned methods, when an end user clicks on an advertisement and goes to a specific web page or mobile app action that a client chooses to measure, TrackingHub collects information from the user’s device, including but not limited to IP address and ad identifiers.

How May Clients Use TrackingHub To Process Information From End Users?

• Measuring performance of ad campaigns, including creation of customized performance reports
• Measuring performance of various marketing partners selected by the client
• Serving ads through TrackingHub using data that does not personally identify users
• Managing relationships with marketing partners, including payouts on measured conversions and establishing automated workflows to establishing advertising offers

In Which Instances Might TrackingHub Share End User Data With Third Parties?

Except as described in this Privacy Policy, TrackingHub will not share personally identifiable information collected on the Websites or in the TrackingHub Platform with other people or non-affiliated companies unless we have your consent, or under the following circumstances:

• With third party service providers who work for us and need access to your information to do their work on our behalf, such as providing customer support features, processing payments, and storing data (e.g. Amazon Web Services). All such third-party vendors have agreed to protect the confidentiality of information provided by TrackingHub.
• To protect the rights and property of TrackingHub, our agents, customers, users, and others, including to enforce our agreements, policies, and terms of use.
• If required to do so by law, such as to comply with a subpoena or court order, or in the good-faith belief that such action is reasonably necessary to protect our rights, protect your safety or the safety of others, prevent fraudulent, malicious, or unlawful activity, investigate fraud, or respond to a government request.
• As part of any merger, acquisition, debt financing, or sale of company assets or other event in which information could be transferred to third parties as one of the business assets of the company.

We may also share aggregated or anonymized information in a form that does not directly identify you or any end users with any third parties.

Our Website may include links to other websites whose privacy practices may differ from those of TrackingHub. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

End User Choice, Opt Outs, and Disabling Cookies and Advertising Identifiers

We may use cookies to store your individual user preferences in order to make your user experience more enjoyable in the future. Cookies are tiny bits of information stored by your browser on the device you use to access our website. Most browsers are initially set up to accept cookies by default and they are commonly found on many websites throughout the Internet.

End users can disable cookies in most internet browsers. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Disabling cookies will not, however, stop receipt of all advertisements. If an end user would like to opt out of a particular ad network, publisher, or advertiser’s ads, they will need to contact those companies directly to inquire whether they have an opt-out option.End users can also disable collection of Ad Identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the Ad Identifier altogether using their smartphone’s privacy settings. TrackingHub collects data on behalf of its business clients, and is not an end user facing company.

Learn more about how to control your data via our third party partners’ relevant privacy documentation regarding end user rights: Pendo, Intercom, Marketo, Zendesk, NetSuite by Oracle, SalesForce, Google Analytics, LiveChat, TransferWise, and Inspectlet.

TrackingHub Publications

If you no longer wish to receive TrackingHub publications (e.g. newsletters, blog digests), you may opt out using the unsubscribe link located at the bottom of each communication or by updating your preferences. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. We will respond to your opt out request to access within a reasonable timeframe.

Local Shared Objects (Flash Cookies) and Local Storage (HTML5) Opt Out

Third parties with whom we partner may use local shared objects (flash cookies), and we and our third parties use local storage (HTML5) to provide certain features on our Websites, to display advertising based on your web browsing activity, and to store content information and preferences. Various browsers may offer their own management tools for removing HTML 5.

Data Retention, Use, Access, Corrections, and Removal

TrackingHub retains your information for as long as your account is active or as needed to provide you TrackingHub services. TrackingHub applies data retention rules to abide by data minimization principles. In most cases, reliance on TrackingHub’s existing data retention rules will satisfy the end user request within a reasonable period of time. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law and helpful for the service to function properly.

Security

TrackingHub uses commercially reasonable efforts, including a variety of security technologies and procedures, to help protect client and end user data from unauthorized access, use, or disclosure, both during transmission and once it is received.

What Happens If This Privacy Policy Is Changed?

TrackingHub may find it necessary to update this Privacy Policy from time to time. Please check this Privacy Policy, as any changes will be posted on this site.

Questions About This Privacy Policy?

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at [email protected]