Privacy Policy

The Exchange Lab is firmly committed to protecting user privacy and fostering user confidence in the Internet and digital advertising. 

The purpose of this Privacy Policy is to provide clear notice about the information we may collect in connection with our Services (as defined in Section 1 below), including activities we undertake across web sites, applications and other digital properties (collectively, “Sites”), and on our corporate web site, www.theexchangelab.com (“Exchange Lab Web Site”), which is operated by The Exchange Lab Ltd. 

To learn about how we use data and technology as part of our business to provide digital advertising services to our clients, please see Section 1 below. To learn about how we use data and cookies on the Exchange Lab Web Site, please see Section 2 below.

The Exchange Lab is part of the GroupM media investment group; GroupM is part of the WPP, plc group of companies.  Except as expressly stated otherwise, the use of information by our non-Exchange Lab affiliates, our clients, our service providers, and other third parties is not covered by this Privacy Policy. 

Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Policy from time to time.  Accordingly, since we want to help you clearly understand our privacy practices, we encourage you to review this Privacy Policy periodically to become aware of any changes that may have occurred.  You can determine when this Privacy Policy was last revised by referring to the “Effective Date” above. If you continue to use the Exchange Lab Web Site or our Services after such changes, we will take that as an indication that you have accepted the updated terms. 

If you have questions or concerns regarding this Privacy Policy, please contact us through email or by mail.  You can address your general questions and comments by e-mail to privacy@theexchangelab.com or by mail to us at c/o 22 Long Acre, Covent Garden, London, WC2E 9LY, Attn: Legal Department.

Section 1: Exchange Lab Services

Exchange Lab’s Services

We provide a range of services to our clients, including advertisers and agencies. Exchange Lab’s services (“Services”) include: media planning, buying and selling; marketing communications planning; campaign analytics and research; and audience segmentation and data management.  Our clients use our Services in order to help ensure that online users receive the most useful and relevant ads and to determine and improve the effectiveness of that advertising. 

Types of information we collect through our Services

When you view and interact with sites and with advertisements where our Services are utilized, we may collect through our Services information regarding your browsing, usage and interactions.  We may also collect information that identifies browsers and devices we have interacted with previously. Such information collected through our Services may include the type of Internet browser, browser language, and operating system you use, your device’s Internet protocol address (“IP address”), unique identifiers available at or pertaining to your device, connection type (wired or Wi-Fi), region where your device is located, network to which your device is connected, longitude/latitude of a (mobile) device, mobile carrier (if available), the Site and page you came from before, and visited after, viewing an advertisement, and information related to the Site and page you are viewing (i.e., in order to ascertain your interests). Devices include computers, mobile phones, tablets, e-readers, or other digital devices capable of maintaining an Internet connection. 

We do not collect users’ names, mailing addresses, phone numbers, email addresses or similar personally identifiable information through our Services.

We may also receive information from other companies, including our clients, that is collected outside our Services and is provided to us for use in connection with the Services.  We may integrate that information with information collected through our Services.

How we collect information through our Services

The Exchange Lab uses Demand Side Platforms (DSPs) and other technologies to run digital campaigns for clients. We collect information through the use of cookies, advertising IDs, pixels and other technologies.  A cookie is a small text file that is stored in a browser by a web site or ad server which allows that web site or ad server to recognize that browser and remember user preferences and other information.  An advertising ID is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment and remember User Information (defined below) and other information.  A pixel is a line of code that is used by a site or third party to assign online activities to a device or browser.  The use of a pixel allows us to record, for example, that a device or browser has visited a particular site or page.  Additional information from an earlier period or interaction, which may include User Information intended to provide users with more useful and relevant online advertising, may also be associated with such device or browser.

We may collect and utilize information about users and activities across different sites, and associate it across applicable devices and browsers that we have reasonably linked to the same user.  We may also utilize information that we receive from other companies, and associate it with information we collect and across applicable devices and browsers that we have reasonably linked to the same user.  These practices are intended to help ensure that online users receive the most useful and relevant ads regardless of device or browser.

How we use information collected through our Services

We use the information collected through our Services to help ensure that you receive the most useful and relevant online advertising you see on sites (including on web sites in a browser environment and/or in applications, and on other devices and browsers that we have reasonably linked to the device and/or browser where the information was collected) (we refer to customized advertising based on users’ interests, demographic information, prior activity, and similar information (“User Information”), as “Interest-Based Advertising”).  For example, if we think that a user is interested in apparel options, then our Services may help our clients deliver Interest-Based Advertisements to that user about a particular type of apparel. 

Such User Information may also be used to limit the number of times you see a particular ad, and for other purposes such as research, reporting and analysis in order to deliver the most useful and relevant advertising and to determine and improve the effectiveness of that advertising. 

We may also receive from other companies User Information collected outside the Services for use in connection with the Services, also to help ensure that online users receive the most useful and relevant advertising and to determine and improve the effectiveness of that advertising.  We do not associate such information with your name, mailing address, email address or similar personally identifiable information. 

We require our clients to comply with applicable laws governing online privacy.  We encourage you to read the privacy policies of the sites you visit to better understand issues relating to your online privacy.

Disclosure of information to third parties

We may disclose the information we collect about you (see “Types of Information We Collect through Our Services” above), and information derived from it, to our clients and service providers. As we do not collect users’ names, mailing addresses, phone numbers, email addresses or similar personally identifiable information through our Services, we do not disclose any such information to third parties.  However, if you decide to provide personally identifiable information via one of our clients’ advertisements or sites, then that information will be received by that client and will be subject to that client’s privacy policy.  Our service providers are generally not permitted to use non-aggregated information we disclose to them for any purpose other than providing services to us or our clients.

Our affiliate [m]PLATFORM operates and maintains a proprietary data management platform that we and other affiliates may utilize in order to provide services.  The information we disclose to [m]PLATFORM may be used by [m]PLATFORM 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.

User Choice

You may opt out of Exchange Lab Interest-Based Advertising through several mechanisms.

Exchange Lab does not drop cookies, but uses DSPs that do so. You may choose not to receive customized third-party advertisements via Exchange Lab’s DSP targeting cookies on the browser you are using by clicking below, in which case those third-party targeting cookies will be replaced with an “opt-out” cookie, and the Interest-Based Advertising data previously collected or received in association with the replaced third-party targeting cookie will not be used for Interest-Based Advertising on any other 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 Exchange Lab. Opt-out links to Exchange Lab used DSPs are below.

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 Exchange Lab and other service providers via the following methods:

  • You may adjust your browser settings to refuse or remove cookies, which would result in the elimination of Interest-Based Advertising via cookies from Exchange Lab and from other providers in addition to Exchange Lab. 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 aboutcookies.orgwww.youronlinechoices.comand http://www.aboutads.info/consumers#cookies
  • You may adjust the cookie settings at the level of the web site owner where you granted us your consent to our cookie usage, to the extent made available by the cookie settings deployed by the applicable web site owner.
  • You may simply opt out of all Interest-Based Advertising at the following Sites:

In mobile app environments, you may opt out of Interest-Based Advertising from just Exchange Lab DSPs or from both Exchange Lab DSPs and other service providers via the following methods:

  • You may select “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from Exchange Lab and from other providers in addition to Exchange Lab.
  • You may opt out of Interest-Based Advertising via the applicable advertising ID from Exchange Lab DSPs and/or other providers via the AppChoices app.  Please note that, in order for the AppChoices app to function properly, your “Limit Ad Tracking” device setting must not be selected.  Interest-Based Advertising data previously collected or received in association with the replaced advertising ID will not be used via Exchange Lab DSPs for Interest-Based Advertising on any other device or browser that we have reasonably linked to the mobile app environment where the information was collected.  In addition, if we have actual knowledge that another device or browser is linked to the opted-out mobile app environment, that other device or browser will also be opted out from receiving Interest-Based Advertising via Exchange Lab DSPs.  Additional information regarding the AppChoices app is available at http://youradchoices.com/appchoices.

Additional information regarding user choice in application environments is available at www.networkadvertising.org/mobile-choices.

Network Advertising Initiative 

Exchange Lab is part of [m]PLATFORM, a member of the Network Advertising Initiative (NAI) who adheres to the NAI’s Codes of Conduct in those markets where these self-regulatory frameworks apply and are in effect. 

We fully support the digital advertising industry’s efforts to increase transparency in the area of Interest-Based Advertising. 

You can also click here to reach the Network Advertising Initiative site, a central location for information about Interest-Based Advertising and the choices available to you, and to opt out of receiving third-party Interest-Based Advertising via cookies from us and NAI member companies.

Digital Advertising Alliance, European Interactive Digital Advertising Alliance, and Digital Advertising Alliance of Canada

Exchange Lab is part of [m]PLATFORM, a signatory of the Digital Advertising Alliance (DAA), the European Interactive Digital Advertising Alliance (EDAA), and the Digital Advertising Alliance of Canada (DAAC) and, in connection with such memberships, adhere to the DAA Self-Regulatory Principles, the IAB Europe EU Framework for Online Behavioural Advertising, and the DAAC’s Canadian Self-Regulatory Principles for Online Behavioural Advertising, respectively, in those markets where such applicable self-regulatory framework applies.

Enhanced Notice

Exchange Lab supports deployment of the Advertising Option icons (AdChoices and AppChoices) as part of its participation in the DAA’s self-regulatory framework (in the United States), the IAB Europe OBA Framework for Online Behavioral Advertising (in Europe), and the DAAC’s Canadian Self-Regulatory Principles for Online Behavioural Advertising (in Canada).  Advertisements that are provided by organizations that participate in these frameworks will display the icon displayed below when technologically feasible. If you click on the icon displayed on an ad, you will receive information about Interest-Based Advertising.

You can click here to reach the DAA site, which has additional information about Interest-Based Advertising and the DAA’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 DAA member companies.

Children’s Privacy

Neither the Services nor the Exchange Lab 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.  If you believe a child has provided us with personal information and you would like to have the information removed, please contact us at privacy@theexchangelab.com.

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 the “contact us” page) that is in our possession or under our control to the acquiring party.

Information Security

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. Therefore, while we strive to protect such data at all times, we cannot guarantee its absolute security and shall not be liable for any breach of security in relation to any such data.

We are a global company and therefore we may transfer data to countries around the world, including countries outside your country or your continent.  We will, where necessary, put in place appropriate safeguards to ensure such data is protected.

IP Address

Please note that in some countries an IP address is considered personal data by applicable law. We do not collect IP address from these countries.

 

Section 2: Exchange Lab Web Site

How Information is Used and Shared on the Exchange Lab Web Site

We respect the privacy of users of the Exchange Lab 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 your personal information collected via the Exchange Lab Web Site.

What Information Do We Collect? 

When you use the Exchange Lab Web Site, we may gather the following information:

  • Information (which may include personal information such as name, address, email address, and telephone number) provided by you when you submit your CV or a job application to us or request information from us
  • IP address and/or cookie ID

If you provide us information through our “Contact/Contact Us” link on the Exchange Lab Web Site, we may keep a record of the information you provide, including your email address and any other personal information you provide, solely for the purposes of responding to your inquiry or providing you with relevant material and, where you have consented, with marketing communications about our products and services.  We may disclose such personal information to third party marketing automation service providers solely for those purposes; those service providers are not permitted to use this information for any purpose other than providing services to us.

How Do We Use the Information We Collect on the Exchange Lab Web Site?

We will use this information in the following ways:

  • To provide you with information that you have requested;
  • To respond to specific queries you may raise regarding Exchange Lab, its business, the services it provides to clients and any of its group companies;
  • To improve the content, speed, and security of the Exchange Lab Web Site; and/or
  • To process and consider your CV and/or job application. 

Do We Pass Your Information to Third Parties?

We may send your information (including your personal information) 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 Policy. 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 information) to the acquiring party.

We also may disclose your information (including your personal information) 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. 

How Do We Use Your Information for Marketing?

We will only provide you with marketing information that you have requested.

Where Do We Send Your Information?

We are a global company and therefore we may transfer your information to countries around the world, including countries outside your country or your continent. We will, where necessary, put in place appropriate safeguards to ensure your information is protected.

Linking to Other Sites

The Exchange Lab Web Site links to third-party Sites.  A link from any of our own Sites to another Site does not imply our endorsement of that Site.  We do not control the Sites to which we link and are not responsible for their content or their privacy policies or practices.  These Sites may use cookies, pixels, and other technology, and collect your personal information in accordance with their own privacy policies.  Therefore, you should carefully review the privacy policies that apply to any Sites you access from our Site. 

Use of Cookies on the Exchange Lab Web Site

A cookie is a small text file that is stored in a browser by a website or ad server which allows that website or ad server to recognize that browser and remember user preferences and other information.  (For more information on cookies, please see Section 1 above.)  We use cookies on the Exchange Lab Web Site to improve the content, speed, and security of the Exchange Lab Web Site, and to allow you to share pages with social networks.

For more information about the specific cookies Exchange Lab uses on the Exchange Lab Web Site, please click here.

Managing Cookies

For information on how to opt out from, or manage, cookies on the Exchange Lab website, and/or cookies from other service providers, please see the “User Choice” subsection in Section 1 above.

How Do We Protect Your Information?

We take appropriate measures to ensure that your personal information 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.

Children

The Exchange Lab Web Site is not intended or designed to attract children. We do not knowingly collect personal information from children. 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 information, please ask your parent or guardian to do so on your behalf.

 

Section 3: Contacting Us 

How to Obtain a Copy of Your Information

You are entitled to know what personal information we hold about you and to have any inaccuracies in your personal information corrected. For these purposes, please contact us at privacy@theexchangelab.com. 

How to Contact Us if Your Information or Preferences Change

If your personal information or your preferences change, if you don’t want us to send you the information you have requested or if you have any queries about how we use your personal information, please let us know by contacting us at privacy@ theexchangelab.com.