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Innervate

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Innervate (formerly Flashtalking) is a dynamic creative optimisation and ad personalisation platform that uses cookies and identifiers to tailor advertising creative in real time.

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Overview

What does Innervate do?

What is Innervate and how does it work

Innervate is the rebranded Flashtalking platform from Mediaocean. It is a Dynamic Creative Optimisation (DCO) suite that personalises advertising creative in real time based on signals such as audience segment, weather, location, device, and behaviour. The platform serves images, video, and HTML5 creatives, and uses identifiers to attribute conversions back to specific creative variants. Because Innervate relies on persistent identifiers and audience data, it falls fully under the GDPR and the ePrivacy Directive.

Cookies and identifiers used by Innervate

Innervate sets third party cookies on flashtalking.com and innervate.com domains, including the FT cookie (anonymous Flashtalking identifier) and the FCD cookie (frequency capping). It may also synchronise with the buyer's DSP identifier and read audience segments injected by data partners. Cookies typically last between thirty days and thirteen months. All these identifiers are non essential, so consent is required.

Legal basis under the GDPR

Innervate processes personal data for advertising personalisation and measurement, so the legal basis is explicit consent under Article 6(1)(a) of the GDPR, combined with Article 5(3) of the ePrivacy Directive for cookie storage. Legitimate interest is not appropriate for behavioural advertising, as confirmed by the EDPB and the Belgian APD ruling on IAB Europe.

International data transfers

Innervate is part of Mediaocean, a US headquartered group. Although it operates EU edge servers, personal data (cookie IDs, IP addresses, audience signals) may be transferred to the United States for processing and analytics. Transfers are covered by Standard Contractual Clauses and, where the recipient is certified, the EU, US Data Privacy Framework.

Consent management

Integrate Innervate with a Consent Management Platform that supports the IAB TCF v2.2. The CMP must pass the TC string to every Innervate tag before the script fires, and the script must remain inactive until a positive consent signal exists. Honour Global Privacy Control headers when present.

Practical compliance steps

List Innervate, Flashtalking, and Mediaocean in your cookie policy with their purposes and retention periods. Block all Innervate tags server side or client side until consent is granted. Maintain consent proof for at least the duration of the cookies, refresh consent at least every thirteen months, and review your DPIA whenever you onboard new audience segments.

Compliance

Innervate and the GDPR

Innervate is classified as “Marketing”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

Legal basis
Consent (GDPR Art. 6(1)(a) and ePrivacy Directive Art. 5(3))
Risk level
high
Applicable regulations
GDPR, ePrivacy Directive, IAB TCF v2.2

Impact assessment (DPIA)

A DPIA is recommended because Innervate combines audience segments, behavioural signals, and creative personalisation, which can trigger Art. 35(3)(b) of the GDPR. The risks include large scale profiling and onward sharing with measurement and verification partners.

Sample text for your banner

We use Innervate to personalise advertising creative based on your interests. With your consent, Innervate may set cookies, read identifiers, and share data with our measurement partners.
Cookies and trackers

What Innervate sets and contacts

Tracking method
JavaScript tag with first and third party cookies, dynamic creative optimisation (DCO), and audience segment matching
Server location
United States and European Union (multi region cloud)
Data transferred outside the EU
Data is processed on US infrastructure with EU edge nodes. International transfers rely on Standard Contractual Clauses and, where applicable, the EU, US Data Privacy Framework.

Cookies set (5)

NameTypeDurationPurpose
FTthird_party13 monthsAnonymous Flashtalking user identifier used for creative attribution
FCDthird_party30 daysFrequency capping of creative variants
CK_avthird_party12 monthsCookie sync token shared with DSP partners
FT_TCFthird_party12 monthsStores TCF v2.2 consent string read before each creative request
FT_optoutthird_party5 yearsOpt out flag set when the user declines advertising cookies

Third-party domains contacted (5)

  • flashtalking.com
  • innervate.com
  • servedby.flashtalking.com
  • cdn.flashtalking.com
  • sync.flashtalking.com
Questions

Frequently asked questions about Innervate

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What cookies does Innervate set on my website?

Innervate sets third party cookies on flashtalking.com and innervate.com, including FT (anonymous Flashtalking identifier, thirteen months), FCD (frequency capping, thirty days), and CK_av (cookie sync token, twelve months). Some integrations also store a creative ID in localStorage for attribution.

Is consent required before loading Innervate?

Yes. Innervate cookies and identifiers are non essential, so prior informed consent is required under ePrivacy Art. 5(3) and GDPR Art. 6(1)(a). The Innervate tag must remain inactive until the advertising consent category is granted.

What is the legal basis for processing data with Innervate?

Explicit consent under GDPR Art. 6(1)(a). Legitimate interest is not acceptable for behavioural personalisation and creative profiling, as confirmed by EDPB guidelines and the IAB Europe decision by the Belgian APD in 2022.

Does Innervate transfer data to the United States?

Yes. Innervate is part of Mediaocean, a US group, and personal data such as cookie identifiers and IP addresses may be processed in the US. Transfers rely on Standard Contractual Clauses and the EU, US Data Privacy Framework.

Do I need to run a DPIA before deploying Innervate?

A DPIA is strongly recommended. Innervate enables large scale profiling and combines multiple data sources (audience, weather, device), both criteria flagged by the Article 29 Working Party and national supervisory authorities.

How do I implement Innervate in a GDPR compliant way?

Block all Innervate tags until consent, integrate with a TCF v2.2 CMP, pass the TC string with every request, document consent for the duration of the cookies, and review the audience segment list quarterly. Honour Global Privacy Control headers.

Are there alternatives to Innervate?

Contextual creative tools such as Seedtag or GumGum, server side personalisation that does not rely on persistent identifiers, and direct ad serving via Google Ad Manager without DCO reduce the privacy impact. None match Innervate's full personalisation depth.

How do I update my cookie policy for Innervate?

Add an entry for Innervate (and Flashtalking, its legacy brand) in your cookie table with purposes, duration, and a link to the Innervate privacy policy. Refresh the table whenever you onboard new partners or audience segments.

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