Last Modified: November 8, 2021
Welcome to the CJ Affiliate Privacy Notice (“Privacy Notice”). Commission Junction LLC (“CJ Affiliate,” “CJ,” “we,” “us,” or “our”) is an affiliate marketing company and is part of Publicis Groupe. We’ve created this resource to provide you with valuable transparency and choice on how we might collect, use, and share your personal information as a consumer (or visitor) to the website(s) of one of our affiliate publishers or advertisers.
To make some of our services possible and to make smarter decisions, we need to process consumer personal information. This Privacy Policy is intended to describe how your personal information as a consumer is collected and used by CJ while providing our affiliate marketing services. We believe that your privacy and data protection is essential to the growth and prosperity of the internet, and that a great online experience can provide significant benefits to consumers when done properly. In accordance with these beliefs, CJ strives to create results for publishers, advertisers and consumers in revolutionary ways without compromising privacy.
This Privacy Notice is created and maintained as part of our commitment to provide you with transparency and choice on how we process their personal information. We have taken steps to describe our personal information processing activities as clearly and easy-to-read as possible and encourage you to read the entire Privacy Notice. If you still have questions about our privacy practices, you can always contact us at [email protected].
If you are looking for information on how CJ collects and uses personal information in connection with visitors to our website (cj.com), which includes our clients, prospective clients, business-to-business contacts, please click here to view our Website Privacy Notice.
We may use several capitalized terms throughout this Privacy Notice that may be unfamiliar to you. You can find the definitions to these terms at the bottom of this page, or by clicking here.
When you visit websites and mobile applications, there are almost always third parties working behind the scenes to help provide a great digital experience. CJ is one of these companies and we offer affiliate marketing technology and services that keeps your favorite blogs free, your favorite stores in business, and your experience with brands more relevant. To learn more about CJ and affiliate marketing, watch this video.
Affiliate marketing is the process of a brand (for example, a retailer) paying a commission to a publisher (for example a blog or a news site) for the transactions the publisher helps to drive by promoting the brand’s products or services . Publishers will promote products or services from advertisers to visitors of their properties (examples include websites or mobile applications) and earn a piece of the profit for each transaction generated. CJ operates an affiliate network, which helps publishers and advertisers partner with each other. An affiliate network is the platform used by publishers and advertisers to discover and form new partnerships, define criteria for qualified marketing efforts and is used to ensure that appropriate parties are rewarded for qualified activities.
We have a deep-rooted foundation and culture of privacy and data protection at CJ. We integrate privacy in all aspects of our business, including strategy, product development, delivery, and more. We set a ‘privacy-first’ tone early and often, proactively working to limit our data collection to what is necessary to provide our services.
In that spirit, CJ does not collect, store, process, or allow in our systems any of your personal information that is linked, or is intended to be linked, to an identified individual, such as names, addresses, phone numbers, email addresses, driver’s license numbers, or financial account numbers, which we define as directly identifiable information (“DII”). We have built, and continue to build, all our products and services without the use of any DII.
As part of our Privacy by Design philosophy, we consider and prioritize data protection and privacy throughout the entire lifecycle of the data from before it is collected to when it is ultimately destroyed. We constantly strive to maintain unparalleled visibility with consumers. We provide transparency and choice through our website and encourage the same practice throughout the internet.
Unless voluntarily provided by you, CJ does not collect or use any DII. Instead, CJ only processes pseudonymous personal information. Pseudonymous or pseudonymized personal information is information that does not directly identify a specific consumer without the use of additional information. CJ only collects and processes personal information in a pseudonymous format and has both technical and organizational measures in place to make sure that additional information is not used to identify or link that pseudonymous information to an identified consumer. Some examples of pseudonymous information that we process include IP addresses, Cookie IDs, or referring site website addresses, order IDs, and browsing activity. We do not link or attribute pseudonymous information to DII, such as a your name, email address, or phone number.
Using pseudonymous information allows us to see and understand your journey between publishers and advertisers without revealing to us your identity. In other words, we do not directly identify you using the pseudonymous information that we process. In fact, we have no interest in knowing your DII details, and we work to proactively keep such information out of our systems. We will only ever collect DII if it is expressly provided to us, such as when you contacts us on your own initiative via our contact form or otherwise. Even in these instances, we will not tie this DII to pseudonymous information about you that we may have, such as your site browsing or transaction data.
The majority of the data that CJ processes is machine generated and is collected when a consumer visits and interacts with one of our advertisers or publishers, such as a website or mobile application that leverages our services. Such information includes the following:
· Commercial or transactions information: E.g., information relating to online purchases and actions made by you, order IDs, order timestamps, and other purchasing information of products and services.
· Identifiers and Device Information: E.g., hashed emails, mobile identifiers (such as IDFA or AAID), Cookie IDs, user agent strings which provides browser type and version, and IP address.
· Online browsing activity information: E.g., browsing activity and information on your interaction with a website, application, or advertisement where our technology is deployed, such as clicks, ad impressions, time stamps, referring site URLs, and current site URLs.
· Location data: E.g., location information based on IP addresses.
Information Collected Online:
We collect the types of pseudonymous information identified above in a variety of ways. However, we principally use Reporting Technologies, such as cookies, pixels, tags, or other similar technologies to collect the pseudonymous information we need to provide our services. We leverage these technologies to collect the necessary pseudonymous information from you directly as you navigate or interact with our advertisers and publishers.
Information Received from Clients:
Our clients may also provide us with information relating to their customers, prospective customers, or other individuals, which we handle on the behalf of our clients as a service provider. Our clients are independently responsible to determine how they engage with their customers and determine the handling of their customer data. Under these circumstances, the use of such personal information is subject to the privacy policies of the client’s privacy policies. We are not responsible for the privacy practices of our clients, and accordingly, this Privacy Policy and the rights acknowledged herein do not apply to the data that CJ handles on behalf its clients.
CJ collects pseudonymized personal information for a variety of purposes, as detailed below.
Attribution: CJ primarily uses pseudonymous information to attribute a referral or marketing effort by a publisher to an event or transaction with an advertiser. When a consumer responds to or views an affiliate advertisement served by one of our publishers, we may assign a unique identifier that is tied to that consumer’s internet browser or device, often via a cookie or similar technology. One function of these technologies is to provide CJ with the information needed to facilitate the verification and payment of affiliate commissions to a publisher when a consumer clicks on a link, creates a lead, or makes a purchase directly on an advertiser’s website. Even if the consumer re-visits the advertiser's site directly, CJ is able to recognize the unique identifier assigned earlier, and is able to continue to attribute the consumer’s activities on the advertiser's site and credit the publisher that referred the consumer where appropriate. In other words, if a consumer reads a blog about a pair of shoes and decides to visit that advertiser’s website and purchase that pair of shoes, we would ensure that the blog gets compensated for referring the consumer to that advertiser’s website.
Cross-Device Reporting: We may also collect pseudonymous information across multiple browsers or devices to help us more accurately credit a publisher for their referral or marketing effort. Our cross-device reporting allows us to follow a your journey from a publisher to a potential transaction even if you decide to switch browsers or devices throughout that journey. For example, if you interact with a blog post on your phone referring them to purchase a certain pair of shoes, but later decide to switch to a desktop computer to make the purchase, we would be able to leverage our cross-device reporting technologies to ensure that the blog site is credited for the referral.
Insights and Analytics: CJ also uses the pseudonymous information collected to provide our publishers and advertisers with reports to help with their marketing efforts. This information is generally used by our clients to enhance their ad campaigns, such as by learning where the optimal ad placement is on their website, or learning what type of products or services consumers are more interested in. We will generally aggregate or de-identify any pseudonymous information prior to compiling these reports so that it is no longer technically feasible for the data to be linked to you, your device, or your household (“aggregated information”). For example, to measure the effectiveness of an ad or ad campaign, we may compile a report indicating how many unique individuals clicked on an ad. The report, in this example, would only consist of the ad itself and the total number of unique clicks, with no means for the recipient of the report to relate the clicks back to any particular individual. While many of these reports are at the aggregate level, we also produce reports that contain customer-level pseudonymous information. These reports can help our clients identify areas of growth, such as identifying new partnerships or customer audiences.
Internal Business Purposes: CJ may also collect and process personal information for some of our internal business purposes, such as:
· Auditing transactions, such as, counting ad impressions, verifying positioning and quality of ad impressions.
· Auditing our systems and services for compliance with applicable regulations and standards.
· Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
· Debugging to identify and repair errors that impair existing intended functionality.
· Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of a single interaction.
· Performing services on behalf of our advertisers or publishers, such as maintaining or servicing accounts, providing customer service.
· Undertaking internal research for technological development and demonstration.
· Undertaking activities to verify or maintain the quality or safety of our systems and services, and to improve, upgrade, or enhance our systems and services.
· Other purposes as required or permitted by applicable law, or with your consent.
We only share your information for our limited business purposes, as described in this Privacy Notice, including:
Sharing with CJ’s Partners and Affiliates: We may share your personal information with companies affiliated with CJ under Publicis Groupe for the purposes described in this privacy policy.
Sharing with Service Providers: We may share your personal information with service providers to assist or facilitate in the services we provide to our clients, such as vendors, administrative service providers, technology providers, and carefully selected partners for services including, but not limited to, data validation, enhancement, information verification and suppression services.
Sharing with Third Parties: We may share your personal information and/or aggregated information with third parties including advertisers, promotional partners, sponsors, and publishers, for the purposes stated above in this Privacy Notice, including for attribution, cross-device reporting, and insight and analytics purposes.
Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; and/or (c) respond to claims that any content violates the rights of third parties.
Sharing for Fraud Prevention & Safety: We may share your personal information with third parties or service providers to protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Sharing in the Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing with your Consent: We may also share your personal information for any other purpose with your consent.
In addition to our Privacy by Design philosophy, CJ takes extra steps to ensure that any personal information collected and retained is secured and protected from unauthorized access.
CJ takes steps to help ensure that the data we possess is housed and transmitted securely. 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 employ efforts that are designed to ensure that this does not occur.
CJ retains pseudonymized information collected online for 6 years, at which point such information is disassociated from the applicable consumer. Aggregated/De-Identified reports generated from such data may be retained for a longer period as ad delivery and reporting data.
If you are a California resident, the California Consumer Privacy Act of 2018 (“CCPA”) requires certain additional information be provided regarding your rights with respect to your personal information. Please do not rely on the below information and disclosures in this section or otherwise directed to California residents if you are not a resident of California.
California law allows you to make certain requests about your personal information, including pseudonymous information. Specifically, under the CCPA you have the right to request access to certain personal information we hold about you, to request that we delete that information, and to opt out of the “sale” of your personal information. However, CJ does not “sell” your personal information as defined by the CCPA.
To understand the categories of personal information we have collected in the last 12 months, as well as our purposes for such collection, please review the “Information Collection and Use” section above. To understand the categories of parties with whom we have shared the categories of Personal Data within the past 12 months, please see the “Information Sharing by CJ” section above.
Please note that certain information may be exempt from such requests under California law. We also will take reasonable steps to verify your identity before responding to a request. Since CJ does not maintain any directly identifiable information about consumers, we will verify you by reading the Cookie ID associated with your browser. You can submit requests to access and delete your personal information by clicking here or by contacting us at (833) 982-0087.
We do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
From time to time, we may update this Privacy Notice. Any changes to it will become effective when it is posted to our website. You can determine when this Notice was last revised by checking the “Last Modified" legend at the top of this Policy. Please check back periodically to learn of any changes to this Privacy Notice.
For any additional questions, inquiries, or complaints concerning CJ’s privacy notice, please contact us at [email protected].
If you are looking for our privacy notice as it relates to information collected from our website or our business-to-business contacts, please click here.
If you are a visitor from the EU, please visit our dedicated EU Privacy Policy here.
“Cookies” are small text files that are downloaded and stored onto your device (e.g. a computer or smartphone). Cookies allow us to recognize your device and store information about your preferences or past actions. In this Privacy Policy the definition of “Cookies” includes similar technologies that can write or read information on your device such as “Local Shared Objects” (sometimes called Flash Cookies), pixels and web-beacons. There are many misconceptions about cookies. Cookies cannot erase your hard drive, install programs, or collect PII from your browser or device.
“Reporting Technologies” means any technology, tool, or code (including cookies, pixels, SDKs, APIs, local shared objects, web-beacons, tags, and scripts) that enables access to or storage of information on a device.
“Log files” track actions occurring on Sites and collect data including, as an example, your IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, click data and types of advertisements viewed.
"Pixels or Web beacons" are objects that are embedded in a web page or e-mail and are usually invisible to the user but are used to track a web user’s navigation of a website or collection of websites or pages, interaction with an e-mail, use of mobile applications, the completion of transactions, submittal of applications and browsing behavior.