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 may link to this notice from its privacy policy to give its customers notice about the personal information that Hotwire Media is collecting and making available to the Advertiser on the Advertiser’s behalf when the Advertiser uses Hotwire Media’s services in conjunction with the Advertiser’s marketing activities. The Advertiser may incorporate the following language into its privacy policy. “We use advertising services provided to us by Hotwire Media Ltd through which Hotwire Media collects certain information set out at the following link: www.hotwiremedia.co.uk/hotwire-media-notice-marketing-practices about our interactions with you and makes that information available to us to use in accordance with our privacy policy.”

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.

Details of the personal information that Hotwire Media collects about individuals and uses for its own purposes are set out in the Hotwire Media Privacy Policy.

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).

Use of cookies and tracking technologies

Hotwire Media uses cookies and tracking technologies to deliver the Services as set out in detail in the Advertiser Services Cookies Policy. The Advertiser Services Cookies Policy includes instructions, and for certain cookies automated means, to opt out of the use of such cookies. Advertisers may reproduce the Advertiser Services Cookies Policy in their own cookies policy or include the following sentence (with link) in their own cookies policy: “We use advertising services provided to us by Hotwire Media UK Limited through which Hotwire Media places and reads cookies to provide those services to us – the cookies and information collected through those cookies and opt out / disabling instructions in respect of those cookies are set out here.“.

Call tracking

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.

Tracking code

Hotwire Media may also use JavaScript tracking code to monitor the same activities on the Advertiser’s site. In addition, Hotwire Media Tracking Code will also collect the referrer url, which is the url for the site that the consumer was viewing prior to visiting Advertiser’s site, and the consumer’s browser type (such as Google Chrome or Internet Explorer) and internet protocol (IP) address.

ReWire

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.