Effective March 21, 2016
- What information we collect and how we collect it.
- How we use and share that information.
- The choices we offer you to control the collection, use and sharing of information.
- How to contact us if you have questions or complaints.
Information we collect
We collect information in order to provide better and more relevant advertising to consumers. We may collect this information in the following ways:
- Information you give us. For example, from time to time we offer brand recognition surveys on behalf of advertisers. If you participate in these surveys, we will have access to your survey responses. We do not collect personal information through these surveys. Alternatively, from time to time, advertisers may ask us to collect leads on their behalf. In these situations, if you choose to enter your contact information in response to an advertisement, we will have access to your contact information. This contact information constitutes personal information. “Personal information” is information about a person whose identity can reasonably be determined from the information. Examples are a person’s name, telephone number, or e-mail address.
- Information we get from your use of our services. We may collect information about the services that you use and how you use them, like when you visit a website that uses our advertising services or you view and interact with our ads and content. This information includes:
- Cookies. We may send cookies to your browser in order to support behavioral targeted advertising. With these cookies, we may collect data about websites visited, content viewed, searches on other websites, ad interaction, interaction with advertiser websites and other click and browsing behavior, which are examples of what we call “behavioral information.” None of our cookies contain personal information and we do not collect personal information with these cookies.
- Advertising identifiers. To support behavioral targeted advertising on devices where cookies are not available (such as some mobile phone and smart televisions), we may use identifiers such as Apple’s Identifier for Advertising (IDFA) and Google’s Android Advertising ID (AAID) to collect behavioral information. These advertising identifiers do not constitute personal information.
- Browser information. To support behavioral targeting advertising in situations where cookies are unreliable, we may collect information to identify your web browser in order to collect behavioral information. The browser information collected may vary based on where you are physically located in order to comply with local law. The browser information does not constitute personal information. We may collect:
- a portion of the IP address,
- HTTP header fields,
- cached anonymous identifiers and/or
- Precise Location Data. To target advertising, we may use precise location information, including latitude and longitude.
- Mobile Data. To support behavioral targeted advertising, we may collect and/or use data from mobile devices, such as the content of apps and event information shared by the apps, or information from mobile carriers such as de-identified device location or anonymous identifiers associated with the mobile devices.
- Contextual Data. To support contextual advertising, we may collect data about web pages, including page content and page URLs. We only collect this data about a web page if the owner of the web site for that web page has contracted with us to show contextual advertising on that web page.
- IP addresses. To support targeted advertising campaigns, outside the EU, we may collect your IP address. We also store IP addresses in server logs for anti-fraud and security reasons.
- Web beacons. To determine whether you have opened or clicked on an advertisement, we include a unique identifier in our marketing e-mails called a web beacon or pixel.
How we use information we collect
We use the information we collect to serve advertisements to you and to target and analyze consumer behavior. Our goals are to provide better and more relevant advertising to you and provide useful aggregated analytics to our customers.
We may enhance profiles using cross-device technology. This technology is designed to enable us to provide better and more relevant advertising to you using information collected across various multiple devices you use. For example, you might use browsers on a smartphone, tablet, laptop and a desktop computer, or you may use multiple browsers on the same device. Cross-device technology may tell us that the same user is using multiple devices (or multiple browsers on the same device) either through deterministic methods or by statistical correlation. When we determine that you use two or more devices (or browsers on the same device), we may target advertisements to you across the device (or browsers on the same device).
While we may engage in behavioral targeted advertising for common everyday health topics such as colds, coughs and heartburn, we do not collect data or engage in behavioral targeted advertising based on past, present or potential future medical conditions or treatments or sex life.
We do not create collect or use data in order to specifically target children aged 12 or under. Nor do we collect behavioral information when we run advertising on websites or online services where we have actual knowledge that the websites or online services are directed towards children aged 12 or under.
We do not combine personal information with behavioral information. We sometimes support our behavioral targeted advertising with demographic, categorical or performance information (such as the types of e-mails that users have opened or clicked on in the past) extracted from our e-mail lists, however we always first remove or anonymize all personal information.
We process personal information on our servers in many countries around the world, including the United States. We may transfer your personal information to the United States.
We retain information that is collected and used for behavioral targeted advertising only as long as necessary to fulfill a legitimate business need, or as required by law.
If we are contracted to collect leads (contact information) on behalf of an advertiser, we do not use the contact information for any other advertising campaign, and we do not combine the contact information with behavioral information.
Transparency and choice
People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:
- You can opt out of our web-based behavioral targeted advertising by clicking this big red button:
- You can opt out of our in-app behavioral targeted advertising by changing the settings on your mobile device. On Apple devices, the setting may be under Settings-Privacy-Advertising-Limit Ad Tracking. On Android devices, the setting may be under Settings-Account & Sync-Google-Ads-Opt Out of Interest-Based Ads.
All of these are separate. We do not have personal information in our cookies, for example, so you cannot opt out of behavioral targeted advertising by e-mailing us. Similarly, the big red button requires cookies to work (it sets an “opt-out” cookie), and since cookies do not work in mobile apps, it will not opt you out of in-app behavioral targeted advertising. If you set your browser to block our cookies (e.g., with ad-blocking software), or if your browser does not support our cookies, the big red button will not work and you may still receive behavioral targeted advertising.
The big red button does not turn off all ads. You will still receive non-behavioral targeted ads even if you opt out of behavioral targeted advertising; however, the ads will be less relevant to you. You will not receive any e-mail advertisements from us if you opt out of our e-mail advertising.
We will not collect cross-device information for profiles from a device, or engage in targeting of cross-device advertisements on the device, after you have opted out of online behavioral advertising on the device.
We comply with the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising, the Digital Advertising Alliance of Canada’s Canadian Self-Regulatory Principles for Online Behavioural Advertising, the Australian Digital Advertising Alliance’s Australian Best Practice Guideline for Online Behavioural Advertising, and the IAB Europe EU Framework for Online Behavioural Advertising. As part of our compliance, we deploy the Ad Choices icon in behaviorally targeted ads. For more information, please visit http://www.aboutads.info/choices/, http://youradchoices.ca/choices/, http://www.youronlinechoices.com.au/opt-out/ or http://www.youronlinechoices.com/uk/.
Advertisers and third-party ad networks may also participate in our ad network and may also utilize cookies to deliver advertisements and monitor the performance of such advertisements. Many third-party ad networks have agreed to provide an “opt out” mechanism for their ad cookies. The collection of information through cookies by such third parties will be governed by their own privacy policies and practices, over which Adconion has no control.
Some web browsers include a “Do Not Track” request in the HTTP header. At this time, we do not alter our behavior or change our web services upon receiving a “Do Not Track” request.
How we share information
We do not share personal information with companies, organizations and individuals outside of [a•mo•bee] unless one of the following circumstances applies:
- To fulfill a lead collection contract. From time to time, advertisers may ask us to collect leads on their behalf. In such cases, you may choose to provide your contact information in response to an advertisement. We will share this contact information with this advertiser.
- For legal reasons. We will share personal information with companies, organizations or individuals outside of [a•mo•bee] if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request;
- detect, prevent, or otherwise address fraud, security or technical issues; or
- protect against harm to the rights, reputation, property or safety of [a•mo•bee], our clients, our consumers or the public as required or permitted by law.
We may share non-personal information (in aggregated and/or non-aggregated form) publicly and/or with our partners, like publishers, advertisers or connected sites. For example, we may share information about campaign performance with advertisers.
Accessing and updating your personal information
If your personal information is wrong, we strive to allow you to update it quickly or to delete it, unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).
Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
If you are a California resident you have the right to request information regarding the manner in which we share certain categories of your personal information with third parties. You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. Please contact firstname.lastname@example.org for these requests.
We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. Please be advised that, although we take reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through our website is at your own risk.