Oracle Data Cloud Privacy Policy

1. INTRODUCTION

This Oracle Data Cloud Privacy Policy (also referred to as the ‘Privacy Policy’ or the ‘Marketing Cloud & Oracle Data Cloud Privacy Policy’) informs consumers (‘you’) on the collection, use and sharing (collectively referred to as ‘processing’) of your personal information in connection with Oracle’s provision of marketing cloud and data cloud services designed to help Oracle’s customers’ and partners’ online and offline marketing activities (‘Oracle Marketing & Data Clouds’). This Privacy Policy also explains the choices you have in relation to these processing activities.

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, past purchase behavior or information regarding your online interests. Personal information about you that Oracle may process is also referred to as ‘information about you.’ For more detail about the types of information about you that we may process in the Oracle Marketing & Data Clouds, please refer to Section 4 below.

This Privacy Policy was last updated on May 25, 2018. However, the Privacy Policy can change over time, for example to meet changing business or legal requirements. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our website). To see the previous version of this Privacy Policy, please click here.

2. SCOPE

The Privacy Policy applies to Oracle’s processing of consumers’ personal information:

• (i) provided to the Oracle Marketing & Data Cloud by our data suppliers; and
• (ii) collected by Oracle on its own websites and applications in order to contribute to the Oracle Marketing & Data Cloud.

This type of personal information is referred to as third-party information.

The Privacy Policy does not apply to our customers’ own personal information collection practices or their use of your personal information for marketing and other purposes, including when they use the Oracle Marketing or Data Cloud to send you online advertising. This type of personal information is referred to as first-party information. To find out more about our customers’ use of first-party information about you, you are encouraged to review the relevant privacy policy of the company who collected your information from you or is sending you advertising. Please consult that company if you have any further questions about its use of information about you.

For information about Oracle*rsquo;s processing activities with regard your personal information that is outside the scope of this Privacy Policy, for example any personal information collected on Oracle websites and applications and used for Oracle’s own direct marketing purposes, please refer to https://www.oracle.com/legal/privacy/.

3. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?

Oracle Corporation and its affiliated entities are responsible for processing your personal information described in this Privacy Policy. A list of Oracle entities is available here. Please select a region and country to view the registered address and contact details of the Oracle entity or entities located in each country.

4. WHICH TYPES OF PERSONAL INFORMATION DO WE PROCESS AND FROM WHICH SOURCES?

Oracle may process both offline and online information about you, including information from publicly available sources or third party data providers.

• Offline information about you is obtained by Oracle from its offline partners such as brick-and-mortar retail stores, grocery stores and their associated loyalty card programs, payment card brands, catalog orders and consumer survey programs, and third parties who may not have a relationship with you and collect offline information from their offline partners.
• Online information about you originates from your activities on our sites, or from its online partners, such as advertising agencies and website operators (for example, online retail stores or travel sites). Oracle also obtains online information from third parties who may not have a relationship with you and who collect online information using cookies or similar technologies, such as pixels tags and device identifiers, as you browse the Internet and interact with websites. For more information on cookies and similar technologies used in connection with Oracle Data Cloud, please refer to Section 11 below. For a more comprehensive overview of our online Oracle Marketing & Data Cloud partners, please refer to our Oracle Data Cloud data providers catalog.

Information about you may in some cases directly identify you, while in other cases it may only indirectly identify you. Personal information that is collected offline and that can directly identify you may include, for example:

• name and physical address, email addresses, and telephone numbers;
• demographic attributes, when tied to other information that identifies you;
• transactional data based on your purchases, when tied to other information that identifies you;
• company data such as the name, size and location of the company you work for and your role within the company;
• data from marketing opt-in lists, consumer surveys, or publicly available information;
• For the United States only: derived latitude/longitude from a physical address.

Personal information that is collected online and that may indirectly identify you may include, for example:

• unique IDs such as your mobile device identifier or a cookie ID on your browser;
• IP addresses and information derived from IP addresses, such as geographic location;
• information about your device, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, or the preferred language;
• de-identified or obscured personal information such as hashed email addresses (direct identifiers are removed);
• demographic information such as gender, age, and income range when not tied to information that directly identifies you;
• behavioral data of the internet connected computer or device you use when interacting with websites, applications, or other connected devices, such as advertisements clicked or viewed, websites and content areas, date and time of these activities, or the web search used to locate and navigate to a website.

We may associate personal information about you with interest segments or profiles as part of the provision of Oracle Marketing & Data Cloud services to our customers and partners. Interest segments are a specific group of consumers that share a common behavior or preference used for direct marketing by our customers. Profiles are a set of attributes about a specific consumer or device, or a set of multiple consumers or devices sharing common attributes used for marketing by our customers.

5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

We use personal information for the following purposes:

• a) to enable Oracle Marketing & Data Cloud customers and partners to market products and services to you;
• b) to analyze, develop, improve, and optimize the use, function and performance of Oracle products and services;
• c) to manage the security of our sites, networks and systems;
• d) to comply with applicable laws and regulations and to operate our business.

These purposes are described in further detail below.

a) to enable Oracle Marketing & Data Cloud customers and partners to market products and services to you

We process personal information about you to enable Oracle Marketing & Data Cloud customers and partners to market products and services to you via online and offline marketing activities.

More specifically, Oracle can process information about you:

• i. For online advertising delivered through Oracle Data Cloud partners that display online advertising to you on behalf of Oracle Data Cloud customers.
  
  Example: a marketing professional working for a travel company wants to reach a group of individuals (also known as an audience) that may be interested in its travel specials to Hawaii. The marketing professional uses Oracle Data Cloud to create an audience interested in travel to Hawaii. If you have visited a travel website previously and have expressed an interest in Hawaiian vacations, you may subsequently see advertisements for a vacation to Hawaii because a cookie has been placed on your device that made you part of that travel company’s audience.
• ii. For offline and online campaign measurement, analytics, and development of insights on behalf of our Oracle Data Cloud customers.
  
  Example: a marketing professional working for a travel company wants to better understand if the company’s marketing campaign for travel specials to Hawaii contributed to an increase in their product sales. The marketing professional uses the Oracle Data Cloud to see how many videos were watched or ads were viewed, or whether the ads were clicked on and a purchase was made.
• iii. For enabling our Oracle Data Cloud customers to personalize their products and services, including site optimization, email personalization and dynamic marketing and advertising optimization.
  
  Example: if you have previously indicated an interest in travel to Hawaii and when you visit a travel company’s website, the travel company can display offers for Hawaiian vacations on their homepage.
• iv. For linking Profiles and Segments to enable Oracle Marketing & Data Cloud customers and partners to connect your interest segments across the various browsers and/or devices you may use for the purposes described in this section.
  
  Example: you are interested in vacations offered by a travel company and have clicked on their online advertising. You are logged into several devices (your desktop, smartphone, and tablet) using the same login. Oracle partners have indicated that you are likely the same user across those same devices. The travel company is able to send vacation offers to you (via de-identified cookie ID) to these different devices.
• v. For creating modelled online and offline audiences for Oracle Data Cloud customers’ products and services.
  
  Example: a marketing professional working for a travel company wants to find more customers who are, like you, interested in travel to Hawaii. Oracle Data Cloud looks for common traits between profiles that have expressed an interest in traveling to Hawaii and other profiles where a similar interest can be inferred.
• vi. For enabling our Oracle Data Cloud customers to associate first-party information to certain Oracle Data Cloud identifiers in order to deliver marketing and advertising services to you.
  
  Example: A travel company has its own lists of customers who have purchased travel arrangements with them, with names, emails, and addresses. The travel company wants to be able to reach out to these customers with online advertising. This involves converting their own customer lists from identified names, emails and addresses, to de-identified groups of cookie and device ID’s, in a process known in the advertising industry as “onboarding”.
• vii. For the United States only: to allow our customers to deliver catalogues to your physical address that may be of interest to you based on your previous purchase behaviour.

b) to analyze, develop, improve, and optimize the use, function and performance of Oracle products and services

We may process personal information for Oracle’s own research and development purposes.

For example: to enhance data quality, develop new features and functionality, and for statistical analyses related to the performance and operation of the Oracle Marketing & Data Cloud.

c) to manage the security of our sites, networks and systems

We can collect usage and systems operations data from the Oracle Marketing & Data Cloud for security and operations management to help keep our networks and systems as well as our products and services secure, or to investigate and prevent cyber-attacks or potential fraud, including ad fraud and to detect bots.

d) to comply with applicable laws and regulations and to operate our business

In some cases, we may process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the operation of our business. For example, to conduct audits and investigations, for finance and accounting, archiving and insurance purposes.

6. FOR EUROPEAN UNION (EU) RESIDENTS, WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?

For personal information collected about you in the EU/EEA, our basis for processing is the following:

• We rely on your consent to enable Oracle Marketing & Data Cloud customers and partners to market products and services to you and to develop and improve our Oracle products and services. Your consent is obtained on behalf of Oracle and its Oracle Marketing & Data Cloud customers and partners by our data providers. Please refer to Section 12 below for more details on how to opt out of interest-based data processing based on your consent;
• We rely on our legitimate interest to provide measurement and analytics on campaign performance and to analyse, develop, improve and optimize our sites, products, and services and to maintain the security of our sites, networks, and systems. To the extent it is recognized to constitute an appropriate legal basis, we may rely on legitimate interests to enable Oracle Marketing & Data Cloud customers and partners to market products and services to you;
• In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

7. FOR WHAT PERIOD DO WE RETAIN INFORMATION ABOUT YOU?

Oracle maintains personal information for the following retention periods:

• a) Online information about you is retained for up to 13 months.
  
  Exceptionally and for online information collected outside the EU/EEA, online information may be retained up to 18 months, for example for Oracle customers’ seasonal or cyclical interest-based advertising campaigns or internal analytics and model development.
• b) Online information about you for cross device/cross-context technology is retained for up to 12 months.
• c) Offline information about you may retained for up to 5 years if you are located in the EU/EEA. We retain offline information about you in other jurisdictions as needed for business purposes.
• d) Personal information needed to retain opt-out preferences is retained for 20 years unless you delete it or otherwise prevent its collection as further described in Section 12 below.

8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

Sharing within Oracle

As a global organization, information about you can be shared globally throughout Oracle’s worldwide organization. A list of Oracle entities is available here. Please select a region and country to view the registered address and contact details of the Oracle entity or entities located in each country.

Oracle employees are authorised to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties:

• Oracle Data Cloud customers and partners, including digital marketers, ad agencies, web publishers, demand side platforms, data management platforms, supply-side platforms and social media networks;
• third-party service providers as necessary to perform Oracle Marketing & Data Cloud services on behalf of Oracle;
• relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings;
• as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy and in accordance with applicable law.

9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

Oracle is a global corporation with operations in over 80 countries and personal information is processed globally. If personal information is transferred to an Oracle recipient in a country that does not provide an adequate level of protection for personal information, Oracle will take measures designed to adequately protect information about you, such as ensuring that such transfers are subject to the terms of the EU Model Clauses.

Oracle also complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention when an Oracle Data Cloud customer and Oracle have agreed by contract that transfers of personal information from the European Economic Area ("EEA") or Switzerland will be transferred and processed pursuant to the Privacy Shield for the relevant services. When conducting those activities on behalf of its EEA or Swiss Oracle Data Cloud customers, Oracle holds and/or processes personal information provided by the EEA or Swiss customer at the direction of the customer. Oracle will then be responsible for ensuring that third parties acting as an agent on our behalf do the same. Oracle has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Please see the Privacy Shield website for the list of entities covered under Oracle’s Privacy Shield self-certification. With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Oracle is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and commits to cooperate with EU data protection authorities.

10. HOW IS INFORMATION ABOUT YOU SECURED?

Oracle has implemented appropriate technical, physical and organisational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, as well as all other forms of unlawful processing.

11. WHAT COOKIES, PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES DO WE USE?

Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Oracle and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.

Cookies are small text files that contain a string of characters and uniquely identify a browser on a connected device. We or our Oracle Marketing & Data Cloud partners may use cookies to, among other things, track user trends and collect information about how you use our customers’ sites or interact with advertising. Most browsers are initially configured to accept cookies by default. You may, however, be able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. Check your browser’s “help” files to learn more about handling cookies.

Pixel Tags (also called web beacons or clear GIFs) are invisible 1 x 1 pixels that are placed on webpages that use this technology for marketing and measurement purposes. When you access these webpages, pixel tags generate a generic notice of the visit. Pixel tags can be used with cookies or alone. When used with cookies, pixel tags can track activity on a site by a particular device and provide relevant online advertising to you. When you turn off cookies or have opted out of cookies, pixel tags simply detect a unique website visit and how you interacted with the advertising but do not track an individual to provide relevant online advertising.

You can opt out of cookies using the opt-out tools in the next section.

12. WHAT ARE YOUR CHOICES?

We provide multiple choices in respect of the information we process about you. You can exercise these choices as described below.

Opt-out and object to our use of personal information

Oracle offers multiple ways for you to opt out and object to our use of your personal information as described in this Privacy Policy:

• Oracle Data Cloud Opt out. You can access the Oracle Data Cloud opt-out tool here.
  
  Please note that if you use this opt-out tool, Oracle will opt you out of Oracle’s use of your information for Oracle Data Cloud services involving both first-party use of your information as well as any third party use of your information. See Section 2 above for more information on the distinction between first party and third party information.
• AdTech Industry Opt Out. You may also opt out of our processing of your personal information for Oracle Marketing & Data Cloud services by using the opt-out tools provided by the following industry groups:
  • Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/
  • Network Advertising Initiative (NAI): http://www.optout.networkadvertising.org
  • European Interactive Digital Adverting Alliance (EDAA): http://www.youronlinechoices.eu/ and http://www.edaa.eu/
  Oracle’s participation in these organizations may appear under the “BlueKai” or “Datalogix” names.
• Mobile Opt Out. While the opt out methods described above often work for mobile web browsing, mobile ‘app’ environments do not accept cookies. You may want to consider installing the AppChoices App provided by the Digital Advertising Alliance (DAA)to exercise opt-out control for specific companies, including Oracle, when in a mobile app environment. More information on how to download and configure the AppChoices App relevant for your mobile platform is available here.
• Do Not Track. Oracle honors “Do Not Track” browser settings, meaning we will not track your browser for marketing purposes while you have “Do Not Track” turned on in your browser settings.

Please note that if you opt out using any of the first three opt out tools, you may still temporarily receive marketing due to marketing campaigns already underway. However, you will be opted-out of all future marketing campaigns that use the Oracle Marketing & Data Cloud.

Also note that the first three opt out tools are currently cookie-based and prevent Oracle from using your personal information for interest-based advertising on the browser on which they are installed. As a result, the opt out will only function if your browser is set to accept third-party cookies and may not function where cookies are sometimes automatically disabled or removed (e.g., certain mobile devices and operating systems). If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again. Oracle does not use persistent, unique identifiers to revive a previously opted-out profile or deleted cookie.

Delete personal information

You can erase or delete your online information about you by opting out of Oracle Data Cloud services using the Oracle Data Cloud opt-out tool above.

If you would like to submit a request to have your offline information erased or deleted, you can use this form.

Access personal information

In order to exercise your right to access your online information stored in the Oracle Data Cloud, you can use the Oracle Data Cloud Registry (‘Registry’) to view the online segments Oracle has associated with your device. By accessing this Registry, you can view the types of third-party interest segments that are available for Oracle Data Cloud customers. Please note that the interest segments you see within the Registry is information about you from the profile associated with the specific browser, computer or device that you are using to visit the Registry. You may see different segments when viewing the Registry from a different browser, computer or device. We therefore recommend using different browsers and devices when accessing the Registry.

For a copy of your offline information, please contact the Oracle Global Data Protection Officer as set out in Section 16 below. While the majority of offline access requests can be handled quickly, complex requests may take more research and time. In such cases, you will be contacted regarding the nature of the request and appropriate next steps within one month from the date of receipt of your request. We cannot provide first-party information that is collected and maintained by our customers. If you have questions in regards to first-party information, Oracle recommends that you contact directly the company that collected it from you.

13. DOES THE ORACLE DATA CLOUD COLLECT SENSITIVE PERSONAL INFORMATION?

Oracle does not create any online interest segments that reflect personal information that we consider sensitive. While the types of personal information considered sensitive may vary among consumers and applicable law, we treat the following types of personal information as sensitive:

• precise health information, such as a consumer having a certain medical condition like cancer or diabetes. If you would like to view the current list of third-party health and wellness interest segments available in the Oracle BlueKai Marketplace, please click here (PDF);
• certain aspects of a consumer’s personal life or financial situation;
• interest in “adult” products or services;
• information considered sensitive based on applicable law.

We do not allow the Oracle data services to be used for employment, credit, healthcare, or insurance eligibility purposes.

14. DOES THE ORACLE DATA CLOUD COLLECT PERSONAL INFORMATION FROM CHILDREN?

We do not intentionally collect personal information from, and do not tailor any services to, children under 16 years of age. Further, we prohibit our Oracle Data Cloud partners from providing Oracle with personal information from sites directed to children under the age of 16 or from consumers whose age these companies know to be under the age of 16.

15. IS ORACLE A MEMBER OF ANY INDUSTRY ORGANIZATIONS?

Oracle is a member of, and adheres to, the self-regulatory principles of the following industry organizations:

• the Data Marketing & Analytics (ANA)
• the Direct Marketing Association UK (DMA UK);
• the Network Advertising Initiative (NAI);
• the Interactive Advertising Bureau (IAB);
• the Digital Advertising Alliance (DAA);
• the Digital Advertising Alliance of Canada (DAAC); and
• the European Digital Advertising Alliance (EDAA).

As a member of these organizations, Oracle works with industry-leading companies to address important privacy and consumer protection issues in offline direct marketing and online advertising.

The NAI has created a compliance program that incorporates attestation reviews, a consumer complaint process, sanctions and annual reporting to help ensure that member companies keep their promises to you and abide by the NAI’s Self-Regulatory Code of Conduct.

16. HOW TO CONTACT ORACLE IF YOU HAVE QUESTIONS, COMMENTS OR COMPLAINTS?

Oracle has appointed a Global Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, or if you wish to exercise your right to access to your offline personal information as described in Section 12 above, please contact the Global Data Protection Officer by filling out an inquiry form.

Written inquiries to the Global Data Protection Officer may be addressed to:

Oracle Corporation
Global Data Protection Officer
10 Van de Graaff Drive
Burlington, MA 01803
U.S.A.

17. DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.

If you have an unresolved privacy or data use concern that you believe we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, specified on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. You also have the right to file a complaint with a competent data protection authority if you are a resident of a European Union member state.

18. ORACLE CORPORATE HEADQUARTERS

Oracle’s corporate headquarters are located at:

500 Oracle Parkway
Redwood Shores, CA
94065, USA

Tel: +1.650.506.7000
Fax: +1.650.506.7200

Last Updated: May 25, 2018