HOTWIRE MEDIA NOTICE OF MARKETING PRACTICES
Last Modified on 19 April 2016
Information collection through use of Hotwire Media services
This notice sets out what personal information is collected and made available by Hotwire Media Ltd, to its clients (“Advertisers“) who use its Services. It also describes how that personal information is collected and in relation to cookies and tracking code sets out how the Advertiser’s customers can opt out of that collection. When an Advertiser contracts Hotwire Media to provide a service Hotwire Media collects that information on behalf of the Advertiser as the Advertiser’s data processor or agent. Without the Advertiser’s instructions Hotwire Media will not collect the personal information detailed in this notice.
The Advertiser remains responsible for obtaining any required consents and for complying with laws applicable to its use of the Hotwire Media service and the personal information that is stored and made available to it under its direction by Hotwire Media and must notify its customers about this processing in its published privacy practices.
Hotwire Media may change the services and as a consequence the personal information it collects on behalf of the Advertiser or means of collection. If it does so, it will update this notice. Advertisers should therefore check this notice from time to time and ensure that any changes are notified to their customers.
Hotwire Media services collects information through the following means (the corresponding collection method is set out opposite the relevant Hotwire Media service).
On the modified version of the Advertiser’s site, Hotwire Media changes the Advertiser’s phone number to a different number that is provisioned for the Advertiser so that Hotwire Media can provide the following facilities to the Advertiser.
Except where the Advertiser requests Hotwire Media not to do so, Hotwire Media records the calls and the number they were placed from (unless the customer withholds its number) and makes the call recordings available to the Advertiser for up to 90 days so that the Advertiser (and Hotwire Media as its consultant) can assess the quality of the leads the Advertiser is getting through Hotwire Media’s advertising.
Hotwire Media plays a recording in advance of the call notifying the Advertiser’s customer that the call is being recorded so that the customer may hang up if he or she does not want to be recorded. In addition, the Advertiser must notify all of its employees that their calls may be recorded and ensure that such recordings and notifications comply with all laws, regulations and practices relevant and/or applicable to its business.
Hotwire Media does not use the call recordings for its own purposes.
Following a visit to the Advertiser’s site, ReWire allows Hotwire Media to serve an ad for the Advertiser’s site or products or services on third party sites. Hotwire Media is able to do this through its ad network providers dropping cookies on the Advertiser’s customer’s browser when he or she visits the Advertiser’s site and third party sites in the ad network provider’s network (“Ad Network Sites“). When the customer visits an Ad Network Site, the ad network reads the remarketing cookie dropped when the customer visited the Advertiser’s site and causes a further ad from the Advertiser to be displayed on the third party site.
During this process Hotwire Media and/or its ad network providers, through the cookie and pixels in the Advertiser’s site, collects the referrer url (which is the url for the site that the customer was on prior to visiting the Advertiser’s site), user agent (which is the customer’s browser type), IP address, date and time, and domain type of the customer. This information is used to increase the effectiveness of the remarketing for example by displaying the ad subsequently and limiting the number of times the customer sees the same ad. Neither Hotwire Media nor the ad network provider build up profiles of third party sites that the customer has visited, and the information is not shared with other third parties for marketing purposes; the information is used only to remarket the Advertiser’s site or products or services.
Hotwire Media’s subcontractors
Hotwire Media may use subcontractors to provide the services set out above. Where relevant, any additional use of personal information that such subcontractors make will be set out in their privacy policies linked to in the Advertiser Services Cookies Policy.