Privacy Policy for Twitter Remarketing

Twitter Remarketing allows businesses to use Twitter to reach a larger audience of potential customers and gain more followers for Twitter account of a business.

Because remarketing tracks visitors' activities and uses cookies to do so, issues of privacy are raised.

If you use any form of remarketing, your Privacy Policy must be updated to inform visitors of this practice, and visitors must be given a way to opt out of the remarketing tracking done by the third parties you work with.

It's important to note that this legal requirement isn't limited only to Twitter's service, but to all remarketing platforms: AdWords, AdRoll, , Perfect Audience, AppNexus.

Twitter has its own requirements for what policies advertisers must provide, and what information must be included. Both website and mobile apps are covered.

In the FAQ section for the website tag for remarketing, the very first FAQ informs businesses that there are specific policies that must be used when using website tags:

This FAQ is linked to a Twitter Support article about "Policies for Conversion Tracking and Tailored Audiences".

Whether a business uses Twitter Remarketing on a mobile app or on a website (or, most commonly, both), Twitter states that you must provide legally sufficient notice that:

1. The business is working with a third party to collect user data through the website or mobile app
2. This data is collected with the purpose of conversion tracking and serving targeted ads
3. A user can opt-out of this data collection and interest-based advertising, and must provide instructions on how to do so

Twitter also provides an extensive list of what types of tailored audiences are prohibited, such as targeting ads based on religious affiliation or beliefs, negative financial status or condition, or race.

Twitter provides a simple way for Twitter users to opt out of tailored ads and provides this information to visitors in a "Privacy Controls" section. Logged-in users can go to their "Account Settings" and uncheck the box next to "Promoted Content."

Additional information is provided for how tracking can be limited or disabled on both a web browser and mobile device including both iOS and Android-specific information:

Examples of Privacy Policy clauses that might meet Twitter's requirements

Here are some examples of companies and their Privacy Policies that are using the remarketing with Twitter and how each of the following required components has been met.

Remember, a Privacy Policy must include the following information:

• It must let visitors know that your business is working with a third party to collect user data through the website or mobile app,
• That this data is collected with the purpose of conversion tracking and serving targeted ads, and
• That a user can opt-out of this data collection and interest-based advertising, and how this can be done.

Girl Scouts of the United States of America

The Girl Scouts of the USA engages in remarketing and has an updated Privacy Policy to reflect this use of marketing service. Its Privacy Policy is linked in the footer of the homepage for convenient access and conspicuous placement:

Their agreements include all of the required information in one short paragraph, seen below.

Note how there is no specific mention of using Twitter Remarketing service, just a mention of third-party advertising companies.

Visitors are informed that non-personally identifiable information may be collected by third-party advertising companies, which can include Twitter and others, in order to show advertisements.

Rather than giving step by step instructions on how a user can opt out of this third-party tracking, a link is provided to AboutAds, a website where visitors can fully customize their advertising experience and opt-out of the use of cookies by these third-parties.

This is a completely fine and acceptable way of covering all required pieces of information.

Goldie Blox

The Privacy Policy of Goldie Blox is linked within the "Useful Resources" section found in the website footer:

Goldie Blox's policy has a separate section titled "Third Party Tracking and Online Advertising" where all relevant information is included. Visitors are informed that data about their browsing behavior and use of the Goldie Blox website may be collected via cookies or similar tracking technologies and that the information is collected so that relevant ads may be displayed both on the Goldie Blox website and other websites.

Opt-out links are provided, as well:

Vistaprint

Privacy Policy of Vistaprint puts all of the third-party advertising information in a paragraph within the "Cookies and Similar Files" section.

While all of the required information is included here, and visitors looking for information about cookies will be able to find everything in one thorough section, breaking down the third-party advertising information into its own section can help visitors realize that cookies and their personal information are used in different ways, both by your website and by third parties.

TripCase

TripCase informs visitors about their use of remarketing via a "Cookies and Other Technologies for Use of the Services" section in its Privacy Policy that cookies (or alternatives to cookies such as Adobe Flash objects) may be used by the TripCase website, mobile app, emails, and advertisements.

Visitors are informed that collected information "will also be provided to our third party providers, advertisers, advertising networks and platforms, agencies and partners."

The next section in their agreement deals with "Online Behavioral Advertising" and continues to inform visitors how cookies are used by "third party service providers, advertisers, advertising networks and platforms, agencies, and partners...for online behavioral advertising."

The consumer opt-out information and links are provided for convenience and compliance:

Note how TripCase separated the "Online Behavioral Advertising" section from the general "Cookies" section.

This helps visitors understand that you're not only using cookies, but are also allowing third parties to use cookies, and are doing so not only for an enhanced experience while on your website, but also for off-site advertising.

Rock Creek

Rock Creek's Privacy Policy, or Privacy Pledge as they title it, is very short. The entire Policy is just 7 bullet points long.

The section that deals with remarketing states in part that, "We also use cookies to deliver content specific to your interests. Please refer to our third-party advertising tools' individual privacy policies."

AdRoll is then linked, as well as a general informative website about interest-based advertising.

While this article is focused on remarketing through Twitter and Rock Creek uses AdRoll, this example is included to highlight how it doesn't matter if you use Twitter Ads and then AdRoll or another third party advertising platform.

No matter what platform you use for your remarketing, you'll need to update your Privacy Policy.

In all of the above examples before Rock Creek didn't specify which platform was used. "Third party advertising" will encompass everything from AdRoll to Twitter, and could be sufficient language for your Privacy Policy agreement.

Aceable

Aceable includes remarketing information in a "Disclosures" section of its Privacy Policy.

This section is written in very user-friendly language that states how, "As you browse Aceable, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other sites based on your previous interaction with [company website]."

Aceable lets visitors know that personal information such as names, addresses and telephone numbers aren't collected. An opt-out page link is provided:

While AdRoll is specifically mentioned, Aceable could have left that out and just said that their "display advertising partner" enables them to present retargeting ads. This could then work for Twitter, or any other retargeting platform such as AdWords, AppNexus or Perfect Audience.

Clinique

The Privacy Policy of Clinique page has a linked list of each section included in the policy.

"Targeted Advertising" has its own section. This section is very short but includes enough general information to be adequate. What information is collected, by whom, and what it is used for is all outlined, as well as why this is done, and how a visitor can opt out.

Notice how no specific mention of a third party advertising network is mentioned. This could be AdRoll, Twitter, and any combination of multiple third-party partners:

If you use remarketing through Twitter, or any other third-party advertising platform, you'll need to update your Privacy Policy to show the following information:

• That your business is working with a third party to collect user data through the website or mobile app,
• That this data is collected with the purpose of conversion tracking and serving targeted ads, and
• That a user can opt-out of this data collection and interest-based advertising, and how this can be done.

It's recommended, for clarity and ease of access, to include a separate section within your Privacy Policy that inform users about your use of remarketing through third-party partners. You can also do this through a separate Cookies Policy agreement.

However, some businesses choose to include this information within more broad sections of their Privacy Policies agreements, such as within the general "Cookies Usage" section instead of a separate section or a separate agreement.