Privacy Policy
BrokerBabe by BOOTEC MARKETING (“BrokerBabe”, “BOOTEC MARKETING”, “we”, “us”, “our”) provides solutions for performance marketers. This Privacy Policy is provided to help you understand how BOOTEC MARKETING processes end user data on behalf of advertising networks who use the BrokerBabe platform. 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. 



BOOTEC MARKETING and our clients care 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". This Privacy Policy relates solely to our BrokerBabe product.
Definitions
AD SERVING is the process of delivering an ad to be shown in a web page or a mobile app.

ADVERTISERS Companies (apps, brands) that have a product or service they want to promote.

AD IDENTIFIERS are unique character strings associated with user devices that help monitor and measure user interactions with advertisements and apps. Examples of Ad Identifiers include IDFA (developed by Apple for the iPhone), Google Ad ID (developed by Google for Android), and Windows advertising ID (developed by Microsoft for Windows Phone). Each of these Ad Identifiers can be reset by the user.

AFFILIATE: An Affiliate is any website that displays advertisements on behalf of an Advertiser. The terms Affiliate and Publisher can be used interchangeably.

CLICKS refers to the instance when a User “clicks” on the advertisement and goes to the offer’s page.

CLIENTS are BrokerBabe clients and may include individual employees of a BrokerBabe client.

CONVERSIONS happen when the User completes the “offer” (e.g. making a purchase on an e-commerce site, installing a mobile app, filling out a survey, or doing some other action).

COOKIES are small text image files stored on your computer either temporarily or permanently to allow websites to recognize users and keep track of their preferences.

GEOGRAPHIC LOCATION DATA can either be precise (identifying the end user’s precise location) or imprecise (identifying the end user’s city or country). In BrokerBabe we collect imprecise geographic data through IP address and/or WIFI networks in the end user’s vicinity. We collect this data to help our clients provide more relevant advertisements and content, and to ensure we comply with country specific requirements.

IMPRESSIONS occur when a User sees an ad for an Advertiser on a Publisher’s site or app. 

INVENTORY is website or mobile app traffic from Users that can be used for advertising

IP ADDRESS is a numerical label attached to any device that connects to the Internet. Most IP addresses are dynamic i.e. the device’s IP address changes and is not persistently tied to any one device. BrokerBabe clients may opt to obfuscate IP addresses from certain jurisdiction.

NETWORK are brokers between mobile advertisers and publishers.

PIXEL TRACKING is website-based and usually works in conjunction with cookies. This registers when the User visits a particular page.

POSTBACKS are server-to-server communications between parties (generally through an API).

PUBLISHERS have Inventory and display ads on behalf of Advertisers.

USERS are end users, specifically individuals on websites or mobile apps that see and potentially interact with BrokerBabe.

What Is BrokerBabe And Why Do Our Clients Use Us?
BrokerBabe is the leading performance marketing platform, used by the world’s top mobile and desktop networks to manage their online advertising relationships. Clients use BrokerBabe to assess the effectiveness of their Affiliate and Publisher relationships – by measuring User clicks and conversions.



Pursuant to the BOOTEC MARKETING Data Pledge, our clients determine the data that they provide to and collect through BrokerBabe. Clients’ use, collection, exportation, or any other use of end user data, including the use of BOOTEC MARKETING products and services, is governed by their own privacy policies and applicable laws, rules, or regulations. 
How Do Clients Collect User Information Using BrokerBabe?
At the direction of our clients, who act as data controllers, BrokerBabe collects the following types of information from Users to help clients optimize and measure their advertising network, affiliate and publisher relationships:
  • Ad Identifiers
  • IP address
  • Cookies
  • Pixel Tags
  • Imprecise Geographic Location Data derived from IP address and/or WIFI networks.
BrokerBabe also collects this information from employees of Clients who access information using their BrokerBabe accounts to maintain up-to-date contact information.

Clients can also choose to view and measure information provided by other third-party sources in the BrokerBabe platform. Those sources may include: Advertisers, Publishers, Affiliates, and other Networks and analytics partners. Affiliates may sign up with Advertisers through the BrokerBabe platform or through their own customer website. Affiliate information provided to our Advertisers will be used by BOOTEC MARKETING for fraud prevention purposes and to fulfill contractual requirements with our Advertisers. 

Clients own the data that they provide to and collect through the BrokerBabe platform. When clients remove or export their data from the BrokerBabe platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations. BrokerBabe by BOOTEC MARKETING 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 BrokerBabe client.
How Do Clients Use BrokerBabe To Collect Information From Users?
Clients use BrokerBabe for pixel or server postback tracking to collect information about Users. Pixel tracking (also called "cookie-based tracking" and "client-side tracking") methods store a BrokerBabe session identifier in a user’s browser cookie on click. In postback tracking (also called "server-side tracking"), BrokerBabe directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to BrokerBabe for validation. BrokerBabe also supports server-to-server measurement for some clients. With any of the mentioned methods, when an end user clicks on an advertisement, goes to a specific web page or mobile app action that a Client chooses to monitor, BrokerBabe collects information from the User’s computer or device, including but not limited to IP and Ad Identifiers. 
How Do Clients Use BrokerBabe To Process Information From End Users?
  • Measuring the performance of ad campaigns
  • Measuring the performance of Affiliates, Publishers and Networks
  • Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region)
  • Determining when Users respond to ads
  • Ad Serving – BrokerBabe uses data that does not personally identify users to target advertising for Clients. End users can be targeted by device type (OS, Make, Model) and imprecise geographic location (state and region).
What Information Does BrokerBabe Collect From Clients?
Signing up as a Client requires setting up a BrokerBabe account. To do this, we will need contact details – including mailing and/or billing address, email address, company name, and website URL. Clients will also need to provide a user name and password to set up a BrokerBabe account. Please note that BOOTEC MARKETING treats all Client contact details as confidential business information that will only be used to service Client accounts and respond to Client, Affiliate or Publisher inquiries in accordance with a contractual agreement or applicable agreement by and between the partes.
In Which Instances Might BrokerBabe Share End User Data With Third Parties?
BrokerBabe may disclose end user data in the event we reasonably suspect fraudulent, malicious, or unlawful activity, or invalid traffic, or believe that we are legally required to do so. BrokerBabe may also share anonymous aggregated data derived from the BrokerBabe platform, including, for example, statistics about BrokerBabe platform activity. Finally, we may transfer such data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
Can Users Disable Cookie And Id Tracking Through BrokerBabe?
End users can disable cookies in most internet browsers. An overview of the process is available here. 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. End users should also note that BOOTEC MARKETING collects information on behalf of its clients. To opt out, please see www.optoutmobile.com or contact the data controller directly. We will actively work with our clients to fulfill such requests as reasonable and required by law.
How Does BOOTEC MARKETING Adhere to GDPR Principles?
BOOTEC MARKETING serves as a data processor under the GDPR and adheres to the principles and rules of the GDPR. Specifically, BOOTEC MARKETING implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with subprocessors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners. 
EU To US Transfers
BOOTEC MARKETING adheres to the Privacy Shield Principles. To learn more about Privacy Shield, please visit www.privacyshield.gov
Security
BOOTEC MARKETING uses commercially reasonable efforts including a variety of security technologies and procedures to secure client and end user data from unauthorized access, use or disclosure.
What Happens If This Privacy Statement Is Changed?
BrokerBabe 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 a BOOTEC MARKETING client or BOOTEC MARKETING has not addressed satisfactorily, please contact us.
Contact Information
If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at or by mail at: privacy@brokerbabe.com.
Additional Information On How We Categorize And Treat Data:
The Importance of Securing Data in BrokerBabe
At BOOTEC MARKETING, we aim to align our practices with the highest privacy and security standards possible, while also complying with the laws and requirements of the various countries we do business in.
This will help you understand:
  • How BOOTEC MARKETING treats different types of data—depending on whether they are categorized as anonymous, personal or pseudonymous.
  • Why it’s important to secure personal data before sharing with BOOTEC MARKETING or other third parties.
  • Treatment of various data types in BrokerBabe.
Personal, Pseudonymous & Anonymous Data
Under many privacy, security or data protection laws, data is often classified into 3 categories: personal, pseudonymous or anonymous.
 
 Securing “personal” data, or data that can identify an individual person, before “processing” or sharing that data, is a best practice under most privacy and data protection frameworks.
 
 BOOTEC MARKETING clients retain the obligation to (i) provide legally required notices to, and (ii) acquire applicable consents of, end users.
What is Personal Data?
Generally, “personal data” means any information relating to an identified or identifiable natural person. At BOOTEC MARKETING, we treat data as personal depending on the laws of the relevant jurisdiction.
What is Pseudonymous Data?
Pseudonymous data is data that is linked to an end user’s device and cannot specifically identify that end user, but still provides some non-remote possibility of future identification.
What is Personal Data?
Unlike both Personal and Pseudonymous data, Anonymous data is not linked to an end user’s device and does not specifically identify an end user in any way nor provide the potential for future identification of that end user.
Treatment of Various Data Types in BrokerBabe
Included below is a table listing the common types of data uploaded by clients to the BrokerBabe platform and potential BrokerBabe Practice and Use cases.
This list is not exhaustive but is intended to give you a guide on how BrokerBabe treats—and empowers its clients to treat—certain types of data.
Data Type BrokerBabe Practice and Use Cases
IP Address IP addresses from most of the world are considered pseudonymous data. Clients can currently pseudonymize German IP addresses so they are stored in an obfuscated form within their network.
By May 25, 2018, IP addresses originating from the European Union, United Kingdom, and Switzerland will be treated as personal data, and the BrokerBabe client may opt in to obfuscating such data points.
Device IDs Distinctive number associated with a particular handheld device. By May 25, 2018, device IDs originating from the European Union, United Kingdom, and Switzerland will be treated as personal data, and the BrokerBabe client may opt in to replacing such data points with an empty string.
MAC Address Also known as the networking hardware address. By May 25, 2018, MAC addresses originating from the European Union, United Kingdom, and Switzerland will be treated as personal data, and the BrokerBabe client may opt in to replacing such data points with an empty string.
Pixel Tracking Website base code used in conjunction with cookies which registers when a user visits a particular page.
Cookies Small text files to allow websites to recognize users and keep track of their preferences.
User Agent Identifies the type of device and browser, to be used for measurement and targeted advertising.
Referral Link (URL or IP) Allows networks to see where publishers are promoting the offers when available.
Mobile Carrier Based on IP, allows networks to see which mobile carrier a particular device is registered with.
Geolocation (through IP Addresses) Geolocation assists with target advertising in certain countries, states and cities. BrokerBabe utilizes an external service provider to determines the general vicinity of a user based on their IP address.
Please note: BrokerBabe allows clients to configure the product to allow for a variety of data points to be sent to BrokerBabe by BOOTEC MARKETING. This includes Advertiser Identifiers used for analytics, which are not automatically collected as part of BrokerBabe by BOOTEC MARKETING services. Responsibility for configuration of the product and collection of data ultimately resides with our clients. At no time should clients, partners, publishers or ad networks send BOOTEC MARKETING any personal data belonging to end users if proper consent has not been obtained and the data is not reasonably protected.
Data Retention
BOOTEC MARKETING abides by data minimization principles as guided by the European Union’s General Data Protection Regulation. Unless otherwise agreed in writing between the parties, by May 25, 2018, BrokerBabe applies the following data retention rules:
  • IP addresses, Device IDs, and MAC Addresses, regardless of jurisdiction, will have a 120-day rolling data retention window on the BrokerBabe platform (if the data controller does not opt-in to do so earlier). Data scrubbing to occur monthly.
  • All log-level reporting on the BrokerBabe platform will have a 25-month rolling data retention window (if the data controller does not opt-in to do so earlier). These retention windows will only impact the Conversion Report and Click Logs. All Stats Report queries will still be available beyond these retention windows, though Affiliate Sub 1-5 or Source Stats queries are available for 18 months.
  • BOOTEC MARKETING retains client data so long as it is contractually required, and will delete all client data in a reasonable amount of time after the conclusion of our relationship.
  • Additional guidance on end user rights is available at https://optoutmobile.com.