Updated: Jan 17, 2023

About Wellput

Wellput, Inc. (“Wellput,” “We,” “Us,” “Our”)  is a platform for publishers and advertisers to more efficiently buy and sell native sponsored content in email newsletters. Our aim is to help advertisers acquire new customers, publishers to generate more revenue, and subscribers to see more relevant and natively integrated ad content.

What Does This Privacy Policy Cover?

This privacy policy (“Policy”) describes how we collect, use and share data solely in connection with our products and services (“Products”), including the information we receive from our Publishers and Advertisers. This Policy does not apply to information we collect and use on our corporate website, located at www.wellput.io. Please see our Website Privacy Policy for information on our privacy practices as they relate to our company and website. Additionally, the collection of information by our Advertisers and Publishers and their use and disclosure of such information is subject to their own individual privacy policies.

Wellput’s Commitments and Adherence

Wellput supports initiatives of greater transparency, privacy and control for users and adheres to comply with the following industry self-regulatory efforts.

• The Data & Marketing Association. Wellput adheres to the Guidelines for Ethical Business Practice set forth by the U.S.-based Data & Marketing Association (“DMA”). Wellput and our clients honor consumer choices relating to the email marketing offers they may receive. Please visit the DMA for more information about their self-regulatory program.

Quick Reference

• Key Terms

• Wellput Product Overview

• Types of Information We Collect
  How We Use the Information We Collect

• Your Choices

• Access and Managing Personal Information

• Data Security

• Children

• Changes and Updates to This Privacy Policy

• Contacting Wellput

Key Terms

Prior to learning about Wellput’s privacy practices, it may be helpful to familiarize yourself with some of the key terminology we use when describing the technology and processes surrounding Wellput’s data services. We’ve prepared a helpful glossary for you here. Any terms not defined in this policy will have the meaning provided in this glossary.

ADVERTISER

An advertiser is any business that wants to promote its brand, products or services. Advertisers may work with a variety of publishers, technology platforms, and data service providers like Wellput to help them reach their desired audiences.

COOKIE

A cookie is a small text file containing a string of characters that is placed on your browser or device when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. For example, cookies can store your session information for easy sign-in to a website or your language preferences or may allow sites to record your browsing activities – like what pages and content you’ve looked at, when you visited, and whether you clicked on an ad. The site or service that places a particular cookie has permission to read the contents of that cookie each time it communicates with your browser. Some cookies are set by the site you are visiting, and others are set by that site’s service partners.  Cookies may be placed in your browser by third-party advertising companies to help deliver the ads you see online. These “third-party cookies” may be used to “remember” parts of your online activities in order to deliver ads tailored to your interests. For example, if you read a movie review article online, a cookie may be used to note your interest in movies. As you continue to surf the web, you may see coupons to save money at a theater near you.

DATA HASHING

Data hashing is a privacy protection technique that can transform personal information, such as an email address, into a string of random characters. This string uniquely identifies the data in question, but prevents the underlying data (and by extension a particular individual) from being personally identifiable. Unlike other encryption techniques, hashes are not meant to be reversed but may be compared to determine if they represent the same data. Synchronizing various sets of hashed data from multiple sources is at the core of Wellput’s data synchronization services.

DATA PARTNER

Data partners are companies that collect, aggregate, analyze, match, validate and share personal and/or non-personal information for a variety of business uses such as targeted advertising.  Data partners often work with advertisers, publishers, and other intermediaries in the digital ecosystem to help marketers understand their customers, create seamless user experiences across web, mobile and social engagement contexts, and deliver more relevant advertising.

DEVICE

A device is a computer, such as a laptop, tablet or smartphone, that can be used to access our website or be associated with other devices or cookies through our cross-device linking services.

INTEREST-BASED ADVERTISING

Interest-Based Advertising is facilitated by the collection of data across digital properties owned or operated by different entities for the purpose of delivering advertising based on preferences or interests known or inferred from the data collected.

NON-PERSONALLY IDENTIFIABLE INFORMATION

This is information that on its own does not permit direct association with any specific individual in the real-world. For example, we consider the following to be non-personally identifiable information: zip code, browser type, cookie IDs, non-unique device identifiers, websites visited, and advertisements viewed or clicked. We also consider aggregated, de-identified and/or anonymized data to be non-personally identifiable information.

PERSONAL INFORMATION

Personal information is data that can be used to identify or contact a particular individual, such as the individual’s name, email address, phone number or postal address. When non-personal information is directly linked with personal information, this information is also treated as personal information.

PIXEL TAG

A pixel tag is a type of technology placed on a website, or within the body of an email for the purpose of tracking activity on websites or when emails are opened or accessed, and is often used in combination with cookies. Pixel refers to the software code that is placed within a web page in order to trigger the placing of cookies and transmits information to us or our third party service providers. This enables two websites to share information. The resulting connection can include information such as a device’s IP address, the time a person viewed the pixel, an identifier associated with the browser or device, the type of browser being used and the URL of the web page from which the pixel was viewed. A pixel tag is also known as a web beacon or Clear GIFs. There may or may not be a visible graphic image associated with the pixel, and often the image is designed to blend into the background of a web page or email.

PUBLISHER: A publisher is a website or mobile content owner or provider. Publishers are Wellput clients who share de-identified personal information with Wellput in accordance with our Product Privacy Policy and terms of service. Our publisher clients typically use Wellput services to supplement their advertising revenues.

USER

Means an end-user of digital properties and devices, such as a website visitor.

Wellput Product Overview

Wellput Products utilize our ad server API to serve relevant native advertising inside of publishers newsletters. Publishers pass us information that allows Wellput to enhance targeted native advertisements, engage in people-based marketing and perform marketing attribution analysis, all within their newsletters.

Wellput does not have a direct relationship with consumers or other end users, as we work solely in coordination with publishers, advertisers, data management companies, and marketing technology platforms. This Privacy Policy describes our collection and use of various types of information we utilize on behalf of Publishers and Advertisers to assist them in their disclosure obligations to their end users on the Client’s or Data Partner’s website or mobile application, as applicable.

Types of Information We Collect

We receive data hashed personal and other non-personal information from publishers and advertisers through various offline and online sources. We do not intentionally collect or receive information that is deemed by U.S. law to be personally identifiable that is not in a hashed format, such as name, postal address, phone number or email address.

Wellput (or our partners on our behalf) collect the following data to be used in our various products and services: (1) hashed data derived from email addresses or other previously personal information; and (2) website visitor data (including mobile websites) collected via placement of cookies, and other data which helps us link the various data points we need to deliver our Products.

Information Collection

Through the implementation of Wellput’s API, pixel tags and other technologies that our Clients or Data Partners place in their email newsletters and on their digital properties, such as standard and mobile websites, Wellput collects hashed email addresses. The type of information collected through the placement of the pixel may include other commonly associated information from your device or Internet access, such as your IP address, as well as attributes that are unique to the website you visited, ad you viewed, or marketing email you interacted with. These unique attributes help us and our partners link a hashed email to other unique non-personal identifiers.

Information Received from Other Third Party Sources

In addition to data collected from Publishers and Advertisers, from time to time Wellput may work with other data brokers to supplement or append unique user and other non-personal data to our Products. This may include unique user data that is synchronized with third party data providers, inferred data based on interest-categories, or aggregated information. Examples of appended information may include demographics such as gender, age, marital status, regional census data, and income or psychographics such as lifestyle interests. In any case, Wellput does not intentionally collect or receive any information that may be deemed ‘sensitive’, such as protected health information or credit-worthiness.

How We Use the Information We Collect

Our core business is serving and targeting advertising within publisher newsletters. 

For Wellput to serve the most appropriate advertisement, we use the data from our publishers and advertiser clients. Please see the “Your Choices” section below if you do not wish to receive such targeted offers.

We may in good faith also share information (a) as required by law, such as to comply with a subpoena or other legal process or government reporting obligations, or (b) with affiliates, service providers, advisors, and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets. We may also share your data when we believe that disclosure is necessary to (c) protect our rights or the integrity of our business and Products, or (d) your safety or the safety of others.

We may combine, aggregate and share any of the information we collect through our Products for any of these purposes.

Your Choices

You have many options to block, delete or opt-out of Wellput’s ad serving methods. Should you do so, you will continue to receive advertisements in publisher newsletters, however those advertisements may be less relevant to you.Please note that at the current time, we retain collected data for as long as it is necessary to maintain the efficacy of our products.

If you wish for your email address to be removed from any association with Wellput’s Products, please email us at privacy@wellput.io using the same email address you wish to remove. Please include the nature of your request in the subject line of the email. We will cease storing your hashed email address (and any associated IDs) and any targeting based on it. We may, however, continue to use this information for research and development purposes only, unless you are a California resident, in which case the opt out provisions below shall apply to your information.

California Privacy Disclosures

This section provides additional details about the personal information we collect about California residents and the rights they have under California law.

CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

To find out more about the personal information we have collected over the last 12 months, including the categories of sources, please see the Types of Information We Collect section above. We collect this information for the business and commercial purposes described in the How We Use the Information We Collect section above. We do not intentionally collect the personal information of California residents under the age of 16 and do not have actual knowledge that we have sold any such information.

The types of personal information we have sold to our Clients and Data Partners during the preceding 12 months include identifiers (online identifier, internet protocol address, hashed email address), Internet or other electronic network activity information (information regarding your interaction with an internet website, application, email, or advertisement), and inferences about you drawn from this information.

The types of personal information have disclosed for our business purposes during the preceding 12 months include identifiers (unique personal identifier or online identifier), Internet or other electronic network activity information (information regarding your interaction with an internet website, application, email, or advertisement), and inferences about you drawn from this information.

Under California law, California residents have the right to request that we disclose what personal information we collect, use, disclose, and sell. If you are a California resident, upon receipt of a verifiable request we will provide you with the specific pieces and categories of personal information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. Under certain circumstances, California residents also have the right to request that we delete their personal information.

To submit a request to know, request to delete, or request to opt-out, please either submit through this webform or call +1 (800) 357-7078. If you choose to exercise your right to know, delete, or opt-out under California law, we will not treat you differently from any other user unless those differences are related to your information.

In order to verify your request to know or delete information, we may require you to provide us with your first name, last name, and email address. We may also require you to take certain actions, such as clicking on a verification link sent to your email address, or to provide us or our authorized agent with certain information to be used solely for the purpose of verifying your identity. You may designate an authorized agent to make a request on your behalf. You may designate an authorized agent to make a request on your behalf, provided that we are provided with a valid power of attorney and are able to verify the identity of the authorized agent.

SHINE THE LIGHT

Under California law, California residents who have an established business relationship with a company may choose to opt out of that company sharing their personal information with third parties for direct marketing purposes. If you are a California resident and you wish to request certain information regarding our disclosure of your PII to third parties for the direct marketing purposes, please send an e-mail to privacy@wellput.io with “California Third Party Disclosure” in the subject line, or contact us as set forth in the “Contacting Wellput” section below.

RECORD KEEPING OBLIGATIONS

Pursuant to Section 999.317(g) of the California Consumer Protection Act, the number of received and responded to requests made by all individuals (including California consumers) during the 2022 calendar year as follows: