PRIVACY POLICY

EL TORO Data Services and Website Privacy Policy

  1. Introduction to EL TORO’s Services
    El Toro.com, LLC doing business as EL TORO (“EL TORO,” “We” or “Our”) helps our clients, who are generally marketers, advertisers and their agencies and providers, and whom we may engage with directly or indirectly (collectively “Clients”) to tailor their advertising and content to consumers who are most likely to consider them relevant, based on those consumers’ activities, interests and demographics. We work with our Clients across various types of marketing methods and channels, including email, direct mail and display media, including data services and analytics, including those described on this website (our “Website”).You may click here to learn more about how to opt-out of EL TORO’s services.
  2. The Types of Information That We Obtain and Use To Provide Our Services
    EL TORO may receive or collect the following type of information (collectively, the “Information”) 1from a variety of consumer-facing companies and services, data compilers and suppliers, and marketing platforms (collectively, “Marketing Platforms”) as well as from its Clients, when it performs services for those Clients:

    • IP addresses;
    • Personal Information (“PI”) such as first and last name, postal address, and email address, which we may, for instance, link to IP address;
    • Unique individual identifiers that we, our customers or other companies (such as ad and data companies or platforms that we, Clients or Marketing Platforms may create in order to identify a unique (anonymous or de-identified) user’s device or browser. We may use cookies and similar technologies that are linked to these anonymous identifiers. (See our Section 6 titled “Cookies and Similar Technologies That We and Others May Use” for additional background on these technologies.)
    • Hashed values that are derived from PI (such as email addresses) but have been de-identified, through various means.
    • Anonymous information related to unique user behavior, such as the fact that a particular user tends to visit sports websites or entertainment websites.
    • As set forth below in Section 8, we also collect certain Information on our website, that you may provide to us, or that we may collect passively.We may combine, link, or aggregate the above Information with each other. We do not, however, place PI into cookies or associate PI with cookies, and we adhere to the DAA (Digital Advertising Alliance) self-regulatory principles, which are a very prominent industry standard setting forth guidance for consumer privacy protection.
  3. How We Use the Information: The Services We Provide
    We may (but do not necessarily, or always) use PI and other Information we hold or collect to provide a number of marketing-related services, through online display, email and/or direct mail marketing channels. A non-exhaustive list of those types of services is as follows:

    • Targeting of Ads and Content. To provide services that help marketers to target display media to their own customers or to their likely or prospective customers safely and effectively, through various media and advertising channels as described below. For instance, we use the Information to provide services to enable Clients to target “multi-channel” ads to their own customers, prospective customers, or consumers that have visited or logged in to their websites. We, our Clients or their Marketing Platforms may target ads to these customers, whether through email, display media or direct mail. In doing so, we often employ various de-identification and data segregation techniques to safeguard consumer privacy. We also may use or create “Audience Segments” that help us tailor ads and content based on a particular user’s preferences, such as an interest in sports, travel or entertainment.
    • Optimization of Ad Campaigns. To help our Clients to optimize advertising campaigns – for instance, by limiting the frequency or adjusting the sequence of advertising shown to customers. We also may use the Information to customize ads to a particular geographic region, or to the content of a web page on which they are shown.
    • Campaign Measurement. To measure the effectiveness of display media campaigns – for instance, to determine which types of ads are most likely to be seen or opened in what circumstances or by which types of customers, or which types of ads are most likely to lead to clicks, purchases, or other behavior.
    • Other Data Services. We sometimes use PI and other Information to provide other data services, such as (but not limited to) email and direct mail marketing services, and analytics services to help marketers understand and optimize marketing to their own customers.
    • Improving Our Own Products. We may use certain PI and other Information to improve, analyze and develop our own products and services.
    • The above descriptions of our products services are not exhaustive. We provide them to illustrate in a general way the services we offer, and how PI and other Information is used.
  4. How We Respect Consumer Privacy and Choice
    Consumer privacy and choice are important to us. We respect consumer privacy in the following ways, which we believe meet the highest of industry standards. In addition to other privacy and security protections discussed in this Privacy Policy, we adhere to the following:a. We avoid placing PI (as opposed to a unique identifier) into cookies, and when working with data partners we generally “hash” into non-human readable, de-identified form the personal information they receive from us.. In recognition of the importance of separating online data (e.g., browsing data) collected across websites from personal information, we employ other, sophisticated technical, operational and legal means to segregate databases containing PI from that data.b. We do not work with financial or insurance account information, social security numbers, or information about individuals’ health conditions or ailments;c. We provide multiple opt-out channels, as described below in Section 4d. Where required by applicable legal standards, we ask our online partners to provide appropriate notice and choice to their own customers and users.
  5. Your Opt-Out Rights
    You may opt out of the El Toro marketing platform database by accessing our opt out page, here. You may opt out of receiving this advertising from the online Marketing Platforms that we partner with, and learn more about companies that engage in various types of online targeted and retargeted advertising, by visiting the DAA’s opt out page at http://www.aboutads.info/choices.If you’d like to opt out of other third party ad platforms and ad networks (including ones we work with and may have transferred Information to in the past), we recommend visiting the opt-out pages offered by the Network Advertising Initiative and the DAA’s AboutAds program. Opting out in this manner will not prevent you from seeing ads: it will prevent targeted ads customized to what these companies believe are most likely to be relevant and of interest to you. In addition, opting out in this way (or through our opt-out cookie) is browser-specific, so if you change your browser, update it, or clear your cookie cache, you will need to opt out again.
  6. How We Work With and Share the Information With Third Parties
    EL TORO may share Information with Clients, Marketing Platforms, and service providers that we work with or retain, in order to provide the services we have described above (or other services we may add). More specifically:a. Partners: We may share Information with business and data partners (including Marketing Platforms) to deliver ads and to help provide more tailored advertising and for analytical purposes. Likewise, we may do so for analytical purposes, to measure campaigns, or inform future campaigns, or to handle, analyze, or segregate the PI and other data that we handle for Clients.b. Corporate transfers: If EL TORO or its significant assets are purchased by another entity, our Information will be transferred to that entity.c. Affiliates, Parents and Subsidiaries: EL TORO may share some or all of the Information in our possession with affiliated or subsidiary companies.d. As Required by Law or to Protect Any Party: EL TORO may disclose Information if we believe that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of EL TORO or any other party.
  7. Cookies and Similar Technologies That We and Others May Usea. Cookies, Pixels and Similar Technologies
    EL TORO uses industry-standard technologies, including cookies and similarly functional technologies. EL TORO cookies do not contain personal information, and expire within 24 months (and often over a shorter time span than that). However, we may retain purely aggregated versions of the Information (i.e., not tied to a cookie or device) indefinitely.We may work with third parties to provide or enhance our services (e.g. for purposes of retargeting and tailoring ads, or placing browser cookies). These parties may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration period. Those parties may, likewise, collect various types of anonymous or de-identified information about your browser, device, or browsing activities through use of these cookies.Cookies are small data files made up of a string of characters, such as an anonymous unique browser identifier. Cookies are stored on your computer or other device and act as anonymous tags that identify your device, but not you personally. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access these web pages, pixel tags generate a generic notice of the visit and permit us to set or read our cookies. Pixel tags are used in combination with cookies to anonymously track the activity on a site by a particular device. When you adjust your browser settings to stop accepting cookies, pixel tags simply detect an anonymous website visit.We and other Marketing Platforms may use cookies to, among other things, “remember” you, track user trends, and collect information about whether and how you use our clients’ sites or interact with the advertising we deliver on their behalf. We use cookies to provide relevant content to you and replace non-relevant ads with ads that better match your interests.b. Disabling CookiesMost Web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our services may be difficult to use or inoperable.In providing our services, we or other companies we may partner with may (but will not necessarily) work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with our services. These technologies may not respond to browser settings that block conventional cookies. You may opt of many of these types of technologies by visiting the NAI’s opt out page at http://www.networkadvertising.org.
  8. Data Collected Through Our Website
    We also collect data through the website(s) we operate, including any website on which this Privacy Policy is posted, as follows:

    a. Information Collected
    EL TORO collects information from users of our website, including:

    • The domain name and IP addresses of users’ web browsers.
    • A unique identifier (such as in a cookie) that we deploy or read on your browser.
    • Aggregate information on what users’ access, utilize or visit.
    • Information, including Personal Information, that you voluntarily provided to us, such as requests for newsletters, events, and other information, and submission of contact information (such as email address) and (if you decide to accept it) credit card information.

    b. How EL TORO uses the Information We Collect Through Our Website

    We use the information we collect through our website to do the following:

    • Create and manage your unique user account.
    • Provide services to you.
    • Respond to and communicate with you (including regarding news and updates about our services).
    • Send you offers and ads for our products and services, when you browse the Site or other Sites on the Internet.
    • Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you.
    • Perform data analyses (including market research).
    • We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, services, and advertisements offered, including (but not limited to), those provided on or through the services
    • We may use IP addresses to help diagnose problems with our servers and to administer our Site. We also may use IP addresses to help identify visitors to our Site for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our Site, how visitors navigate through the Site, and how we may tailor our Site to better meet the needs of our visitors. We also use the information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.

    c. How EL TORO Shares the Information We Collect Through Our Website

    We may sometimes share, sell or otherwise disclose the Information we collect about you, as described in this Privacy Policy or otherwise disclosed to you when you provide us with the information, including as follows:

    • We may share the Information with service providers who help us deliver the services you request or we provide.
    • We may share the Information to communicate with you and market to you, including through email, direct mail or display media.
    • We will disclose the Information (including PI) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
    • If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process.

    EL TORO’s website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet). For more information about cookies and similar technologies, please go to Section 6 titled “Cookies and Similar Technologies That We and Others May Use.”

    d. Links

    This web site may provide links to other Web sites that EL TORO thinks users will find interesting or useful. EL TORO is not responsible for the privacy practices of these other sites.

  9. Security and Data Integrity
    EL TORO takes various steps to protect the Information we license or maintain, and to house and transmit that Information in a secure way. For instance, this may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we take these steps to ensure that this does not occur.
  10. Binding Agreement; Changes
    We may revise this Privacy Policy at any time, with an effective date posted with it. The revised Privacy Policy will at that time be posted on this website.
  11. Questions or Concerns
    If you have questions or concerns about EL TORO’s privacy efforts or data products, please contact us at:
    Privacy Officer
    EL TORO
    124 N. 1st Street
    Louisville, KY 40202