The following are some of the terms we use frequently throughout this document.
A “User” is an individual who visits websites or interacts with other web-enabled products and services. A user can also be a publisher or advertiser.
A “Publisher” is an affiliated member (“Affiliate”) of the Cornerstone network whose website or other internet traffic source shows visitors advertising links, banner images, and other ad creative to its users. Users who click on these ads are delivered to Advertiser websites, using our tracking links.
An “Advertiser” is a merchant or agency representing a merchant who engages Cornerstone to obtain marketing services and to deliver traffic which originates with our Publishers.
“FlexLinks” is a service offered by Cornerstone to Publishers which enables a publisher to automatically create advertising links on their site.
“Usage Data” includes such information as the device type you use to interact with our site and services. It might also include the type of operating system you use, browser type, ip address, the date and time of any clicks on our advertisements or web pages, broad geographic location (e.g. country or city-level location), and other similar information.
“Personal Information” includes, but is not limited to, contact information such as name, address, email address, or phone number. It can also include other data such as an IP address, mobile advertising identifier, or cookie identifier.
“Cookies” refer to text files stored on a user’s internet-enabled device for tracking services and record-keeping. Some are used to personalize and enhance your experience while visiting websites. Cookies may be session-based, expiring when you close your browser. Cookies are otherwise persistent for varying lengths of time, lasting hours, days, or weeks. A cookie file is referred to as being “dropped” when it saved to your device.
As Cornerstone is an affiliate network enabling advertisements on publisher traffic sources to deliver Users to advertiser websites, users may interact with third parties over which Cornerstone has no control. It is encouraged that you review the privacy policies of those websites and services in addition to this one before sharing any personal data with those organizations.
WHAT WE COLLECT AND WHY
Cornerstone collects information both voluntarily and automatically. For instance, you may voluntarily provide your contact information on a registration form to apply to become a publisher or advertiser on our network. You might voluntarily submit a request for support and provide contact information for us to respond. In each of these voluntary cases, what information we require and the reasons we require it will be clearly stated.
In addition, some information may be collected and processed automatically. For instance, we may record the IP address and the device used to interact with our website and services, along with other usage data, in order to better understand how our services are being used and to improve them. This data may be stored in cookie files on your device.
Data information, including the personal information mentioned above, may also be archived for purposes within the public interest, may be used for historical or scientific research, and for statistical evaluation, where permitted by law.
We may share your information and usage data with third parties and those third parties may also drop cookies of their own when you interact with our websites and services. Examples include Google Analytics to monitor and report on site activity and Zendesk, who provides customer support services. [LINKED LIST?] Data sharing with third parties may also occur to customize and personalize our ad services or to enhance site security. Information may additionally be supplied to law enforcement, a government agency, or another third party as part of a legal matter. In the event of an actual or proposed merger of any part of our business, information may be disclosed to the buyer.
While our legal basis for processing personal information will typically be your expressed consent, we may also process your information when the information is required to fulfill a contract with you or when the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
HOW WE INTERACT WITH PUBLISHERS, ADVERTISERS, AND USERS
Cornerstone.com is an advertising affiliate network whose advertising partners (“Advertisers”) provide us with ad creative and links which we use to track the inbound traffic from Publishers. Users who interact with the link-enabled ad creative found on Publisher websites and other traffic sources are then tracked and delivered to the Advertiser websites where they browse the site, consume their content, submit inquiries, make purchases, or take any number of other actions. Because we interact with all three of these groups, we also collect, store and process information from each as well.
PUBLISHER AND ADVERTISER INFORMATION
When a publisher or advertiser interacts with our website, we may collect personal information and other usage information. Such information includes, but is not limited to, first and last name, address, email address, telephone number, owned website address, banking information, and tax information. In addition, we may collect and store information on how publishers and advertisers interact with our sites and tools. We use the collected information to provide our publishers and advertisers with contracted services, maintain those services, improve existing services, develop new services that meet publisher and advertiser needs, accurately attribute commissionable actions to publisher accounts, properly bill advertisers for our services, communicate with publishers and advertisers, monitor for legal compliance, provide performance reports, and other services.
Publisher and advertiser information can be updated as needed by either editing account information at publisherpro.Cornerstone.com and advertiserpro.Cornerstone.com or by submitting a request by email to su*****@Co********************************.com. It is the responsibility of the account owner to secure their login and password information to protect it.
It is important to note that publisher and advertiser websites and other traffic sources are not controlled by Cornerstone and that owners of those properties are responsible for the creation, updates, and enforcement of their own privacy policies regarding their use. Options to opt-out of tracking from those sites is the responsibility of those publishers and advertisers.
In addition, all publishers are required to follow all applicable laws as outlined in their publisher agreements. This includes notices and disclaimers about their relationship to advertisers as well as their own policies regarding cookies. Publishers should also share what Cornerstone collects from the “User Information” section below as their sites use our tracking links and clicking those links drops our cookies.
Publisher information may be shared with Advertisers to optimize and improve services and revenue yields. It might be shared for compliance purposes or to address legal inquiries. We might share information with Advertisers in order to make business introductions. We retain publisher information indefinitely for compliance purposes such as fraud prevention.
FLEXLINKS FOR PUBLISHERS
We do not intentionally collect any information that would allow Cornerstone to determine the actual identity of users who click on a Cornerstone link created by Flexlinks.
The users described in this document may include those who visit our websites, those who utilize our publisher and advertiser services, and those who click on advertiser tracking links that we provide to publishers and are then redirected to advertiser website locations. When links are clicked, we collect information such as IP addresses, information about the device used to access the link, the referring URL, and other usage information. We cannot and do not intentionally collect information to identify a user. The information we collect and process is used to accurately route the user to the correct destination, credit the publisher for sending the user, provide metrics and analytics to our advertising and publishing partners, optimize aggregated content and conversion rates based on approximated and geographic location, to confirm and correct compatibility issues related to presenting different kinds of advertising to various devices and browsers, and to aid compliance efforts to reduce fraudulent activity.
We store and maintain information we collect for up to three years after which it is anonymized or deleted. If you wish to request the details of any stored information or request its removal, please contact su*****@Co********************************.com with your inquiry.
UPDATES AND INQUIRIES