Connexity Merchant FAQs regarding the EU GDPR
1. How is Connexity complying with the GDPR and other EU data protection standards?
The General Data Protection Act 2018 (“GDPR”) is a comprehensive privacy protection law intended to strengthen the protections individuals have over the use of their Personal Data in the European Union. The ePrivacy Directive is a sectoral privacy directive for EU Member States, and applies to the digital industry. The ePrivacy Directive requires websites to obtain consumer consent before using tracking technology on the user for marketing purposes.
2. What is Connexity’s position under the GDPR?
In relation to Merchants, Connexity is a “Controller” under the GDPR. Connexity, through its affiliate company, Taboola, provides retargeting and personalization services to Merchants, involving using the data collected through Connexity/Taboola technology that Merchants implement on their online properties, for affiliate and behavioral advertising. Under the GDPR, Connexity and Taboola position themselves as Controllers in order to collect and use the data this way.
3. What is behavioral advertising and how does it affect Connexity?
Behavioral advertising is advertising targeted at individuals based on the observation of their behavior over time. Behavioral advertising requires that data subjects consent to the behavioral advertising and be able to opt-out. If cookies or similar tracking technologies are used to store or access information for the purposes of behavioral advertising, the ePrivacy Directive requires that data subjects provide consent for the use of such tracking technologies after having been provided with clear and comprehensive information.
Connexity’s service, as implemented through Pixel(s), now includes the Dynamic Product Ads (also references as “DCO” (Dynamic Creative Optimization)) feature, which involves behavioral advertising by Taboola.
4. What does this mean for Merchants like me and how I work with Connexity?
Given the above requirements, Connexity offers ways for Merchants to pass consent signals to Connexity, and to opt-out of behavioral advertising, including:
i) Our unified pixel is equipped to read and honor:
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- Consent signals, and opt out signals, transmitted through cookie banners and Consent Management Platforms provided by: (1) OneTrust, (2) Didomi, (3) Sourcepoint, (4) Usercentrics, and (5) Cookiebot.
ii) Connexity’s opt-out page at https://connexity.com/opt-out/, or by sending a verifiable consumer request by visiting connexity.com or via e-mail at dataprotection@connexity.com.
iii) Should the user wish to opt out of Taboola's data collection and personalized content, the user may opt out via (1) Taboola's global opt out tool (https://www.taboola.com/privacy-policy#optout), (2) Taboola’s global Data Subject Access Request Portal (https://accessrequest.taboola.com) or (3) an industry-wide opt-out tool that stops all interactive advertising, provided either by the EDAA (available at http://www.youronlinechoices.com).
Merchants should implement a mechanism to obtain/read any consent signals, and opt out signals, and to pass these signals as required under applicable data protection laws. Merchants may also direct their users to the other mechanisms mentioned above.
You can find out more about implementing Pixel(s) in the Merchant Resource Center here, in the “Getting Started” section, or by working with your Account Manager, as applicable.
5. How do you honor a user’s request to opt out of their data being used for behavioral advertising?
Connexity enters into contractual “Processor Agreements” with downstream vendors to ensure they only use data for permissible purposes.
When a user click’s Connexity’s ad opt-out link (on our website), the user is directed to Connexity’s Opt-Out page, at https://connexity.com/opt-out/. Here, data subjects, can instruct Connexity to no longer use their data for behavioral advertising purposes, but this will not prevent Connexity from serving non-targeted ads on the user. Should the user wish to opt out of Connexity’s data collection and personalized content, the user may opt out via (1) Connexity’s global opt out tool (https://connexity.com/opt-out/), (2) by sending a verifiable consumer request by visiting connexity.com or via e-mail at dataprotection@connexity.com, or (3) the DAA’s industry-wide opt out tool that stops all interactive advertising, available via our opt out page mentioned above or at https://youradchoices.com/control).
For Taboola, should the user wish to opt out of Taboola's data collection and our personalized content, the user may opt out via (1) Taboola's global opt out tool (https://www.taboola.com/privacy-policy#optout), (2) Taboola’s global Data Subject Access Request Portal (https://accessrequest.taboola.com) or (3) an industry-wide opt-out tool that stops all interactive advertising, provided either by the EDAA (available at http://www.youronlinechoices.com).
6. Do you collect sensitive data from Merchant users and do users have the ability to restrict it?
Connexity does not collect any sensitive data about Merchant users under the GDPR.
7. Do we need to update our contracts with Connexity?
Our updated Connexity Merchant Terms incorporate the new Merchant Privacy Terms, available at https://connexity.com/merchant-privacy-terms/, which include updated disclosures about the personal data collection and processing activities involved in our service, and expectations of Connexity and Merchants. Merchants should review the Merchant Privacy Terms to ensure they understand their obligations, including the disclosures it will need to provide to visitors of their online properties where the Pixel(s) are implemented, as well as the requirements to collect user consent, and to pass consent and opt out signals to Connexity/Taboola. You should receive a notification of the update to the Connexity Merchant Terms between you and Connexity, which will become effective as detailed in the notification. Otherwise, your Account Manager will be in touch to help ensure that the terms in place will now include the Merchant Privacy Terms.