This document provides guidance on crafting an effective privacy policy that covers all necessary bases and involves key stakeholders. It recommends addressing activities separately under sections like "Privacy and This Site" and "Our Online Advertising" to clearly explain what personal information is collected, how it is used and shared, retention periods, and opt-out options. The document also suggests choosing descriptive language carefully and avoiding words that could be perceived negatively if the policy had to be publicly explained.

1. Questions? Contact Privacy@TruEffect.com to talk to Will about your specific situation
Will Clayton: TruEffect Products and Privacy
Crafting Your Privacy Policy
Cover All the Bases
 Education: Make sure visitors understand what
you are telling them
 Transparency: Tell it all like it is: What, When,
Where, Why, How Long
 Consumer Control: Every data collection has an
appropriate opt-out
 Data Security: Acknowledge your careful
stewardship over visitor data
 Material Changes: Stay Current; Follow Terms
of Collection or Consent
 Sensitive Data: Don’t target children, health
conditions, financial issues
 Accountability: Participate; Encourage; Drive
Best Practices
Involve All Key Stakeholders
 CRM: Personal information collected and used
on-site and in other marketing channels?
o Direct Mail
o Email Marketing
o Other PII-based programs
 Site Monetization: Ad products you sell?
o PII-based data programs?
o Commerce/site recommendations?
o Contribute to behavioral / other networks?
 Site Analysis: How do your site analytics tools
gather and consume user data?
o Is any PII involved?
o Is the data stored in-house or off-site?
o Do you participate in cross-site analytics?
 Executive/Privacy Officer: Accountability
o Does everyone know what you do and why?
o Are they behind your programs?
 IT: Responsible for data retention and security
 Online Advertising Team: What types of online
ad targets and products do you use?
o TruEffect First-Party? Yes!
o Retargeting?
o Behavioral segments?
If you can’t come up with a simple privacy policy
covering all your site activities, you should…
Address Activities Separately
 Privacy and This Site
o We do collect PII if you volunteer it
o You accept the policy upon submission
o We keep your data safe and use it to _______
o We share it with _________
o We retain it for ___________
o We’ll send an email before changing policy
o Click here for an email/phone opt-out
 Our Online Advertising
o Cookies identify interests you’ve shown on-site
o We may use that data to select more relevant ads
for you elsewhere on the web
o This data lives in our domain and cannot be
accessed by others
o We use data only under the policy under which it
was collected (or more restrictive)
o Click here to opt out and see random ads
 Network advertising
o Visible or invisible parts of the site anonymously
identify you to our partners
o This lets them give us first opportunity to select
ads relevant to our existing relationship with you
o Our partners follow privacy standards
o Click here to option out of these and other
network advertising programs
 Other general information and details of your
specific activities as appropriate
Choose Your Language Carefully
Loaded Words Better Words
Target
Profile
…About you…
Hidden
Find
Tracking
Refine
Relationship
Your Interests
Anonymous
Re-engage
Recognition
It’s better to reveal all of your activities up-front than
after you get called out by the Wall Street Journal.
If you would be uncomfortable explaining it to the
public, Don’t Do It!