Privacy Commitment

Last Updated 10/06/14
Protecting your privacy is really important to us at ADARA, Inc (“ADARA”, “we” and “us”) and a key part of protecting your privacy is keeping you informed about our business and how we handle the information we receive. So, we are providing this Privacy Policy to explain how we collect, use, and share the information that we receive about consumers, as well as to explain the options that are available to you. We’ll try to make this all as clear and as simple as possible, but if you have questions, you can contact us at privacy@adara.com, and we’ll be happy to help.

This Privacy Policy covers all of the information that we collect or receive, through our marketing services and from visitors to our company websites adara.com, adaramedia.com and adaraglobal.com (the “ADARA Sites”).


What We Do

ADARA provides digital advertising and analytic services for the benefit of our business customers, giving them the ability to reach Internet users and consumers (like you) who are most likely to be interested in their respective products and services. ADARA provides these services to customers such as website operators and mobile application developers that have installed ADARA Tags or SDKs (“Marketing Partners”). Consumers (like you) benefit from ADARA’s technology by receiving more relevant online marketing content.


Information We Collect from Marketing Partners’ Websites and Apps

We collect and analyze information about individual consumer interests. Our main sources of such information are our Marketing Partners’ own websites and mobile applications. For information about the practices of our Marketing Partners, please review the privacy policy of the Marketing Partner’s website or mobile application – this Privacy Policy only describes the information collection and usage practices of ADARA and not those of our Marketing Partners. When a user visit’s one of our Marketing Partner’s websites (“Marketing Partner Sites”) or views an email from a Marketing Partner with an ADARA Tag or uses an app with an ADARA SDK installed, our servers are notified; and we are able to collect information about what the user does on the website or application, respectively. Tags (also known as pixels tags or web beacons) are tiny graphics that are embedded invisibly on web pages and emails. Tags are typically used in conjunction with cookies to collect information about use activity. A cookie is a small data file that is sent to your computer when you visit a website. ADARA cookies do not include any information that would allow ADARA to identify you individually and personally, such as your name, user name, email address, and physical address (“Personally Identifiable Information or “PII”). When a cookie expires, we no longer use that cookie to collect new information, but we may keep and continue to use the information previously collected.

To serve ads in services where cookie technology may not be available (for example, in mobile applications), we may use anonymous identifiers. Anonymous identifiers are random strings of characters that are used for the same purposes as cookies.

The primary data we collect is information that may serve to identify a computer or device or browser, but does not personally identify any individual person (“Non-Personally Identifiable Information” or Non-PII”). We consider the following types of information to be Non-PII: your zip code, your browser type, your Cookie ID, your unique device identifier, web pages you may have visited, advertisements viewed and items purchased. We also consider aggregated and anonymized information to be Non-PII. Note that we may receive an identifier from our Marketing Partner, e.g., your loyalty ID number, which we may use to collect and consolidate information collected about you across different platforms and websites. We do not collect any PII associated with the identifier provided by our Marketing Partners.

We may also collect the type of data described above across multiple mobile applications. To exercise choice for cross-app data collection, please follow the mobile opt-out instructions in the How to Opt Out section below or download the TRUSTe mobile application, go to “Opt-outs” and select “Adara Media”.

We do not collect PII from you without your knowledge. Only individual consumers themselves ever provide us with PII, and always voluntarily through our website. We never collect PII via the provision of our services to Marketing Partners and other business customers.

We do not knowingly collect or categorize consumers based upon sensitive information, such as racial or ethnic origins, political or religious beliefs, financial information, precise information about health conditions or treatments or other similar or related information.

We neither intentionally collect information from, nor target any services to, children under 13 years of age. If we learn that we have collected PII of a child under 13, we delete that information as soon as possible.


How Collected Information Is Used

We use the information we receive from our Marketing Partners to determine what advertisements or other personalized content might be interesting to you. For example, if any anonymous unique identifier indicated a recently purchased ticket to New York City on a website run by one of our Marketing Partners, we may predict that the identifier might belong to a person interested in seeing advertisements about Broadway plays.


How Information Is Shared

We may share PII and Non-PII with certain third parties selected by us to help support our operations, including improving our website, software or the services we provide our customers. These third parties may have access to your information only for purposes of performing tasks on our behalf, and we contractually require them to protect your information consistent with this Privacy Policy.

We may share the Non-PII that we receive from our Marketing Partners’ websites with the Marketing Partner that permitted us to collect the information.

We sometimes make our Non-PII data available, in aggregated or anonymized format, to our advertising clients, business customers and business partners, and other third parties, for data analysis purposes.

We may transfer all or some of the information discussed in this policy in connection with a corporate merger, acquisition, sale of assets, bankruptcy or other change in corporate status.

We reserve the right to disclose information we receive to government or law enforcement officials or to private parties as we, in our sole discretion, believe necessary to (i) to satisfy or comply with any applicable law, regulation or legal process; (ii) to respond to lawful requests, including subpoenas, warrants or court orders; (iii) to protect our property, rights, and safety and the rights, property and safety of third parties or of the public in general; and (iv) to prevent or stop activity we consider to be illegal or unethical.


Information Collected From ADARA Sites

We collect very little information from visitors to the ADARA Sites. If you provide PII to us, whether by contacting us through one of the ADARA Sites, or by sending it to one of our contact email addresses, we will store that information in our database and will use that information only for the purpose of replying to you. We will not use your PII for analysis or advertising delivery or marketing purposes, unless you specifically authorize the use of your PII for such purposes. We do not share, sell, rent or trade any of your PII to any third party for promotional purposes.

We may also keep track of basic log data for visitors to our sites, like the IP address, operating system, browser type, website visited prior and other non-PII information. We do not permit third parties to collect any PII from you through our site. If you would like more information about this practice and how to control how this information could be used by third parties, please follow one or both of these links: NAI opt out; and DAA opt out.

One of our offerings is a self-serve ad platform (“Self-Serve Platform”). If you register to access and use the Self-Serve Platform on behalf of your company, we will collect only your name, email address, business phone, business address and company name to enable you to gain access to the Self-Serve Platform; and we will use such information only in connection with your access to and use of the Self-Serve Platform.


The Security of Your Information

ADARA cares about your privacy and employs administrative, physical and electronic measures designed to protect your information from unauthorized access. These measures may include encryption of information you provide and employment of information storage security technologies to block access from outside our network. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. Please also be mindful that we are not responsible for the security measures of third parties, e.g. our Marketing Partners. As noted above, for more information about their information collection and usage practices, please see their respective privacy policies.


Data Retention

We use cookies to target and track advertisements and personalize your experience on ADARA Marketing Partner sites. We set our cookies to expire after two years; however, as is the normal practice in our industry, the two year expiration date is extended each time the cookie we gave you encounters our server or to the extent that we continue to provide our services. We do not use cookies to obtain PII. We do not link the information we store in cookies on ADARA Marketing Partner sites to any PII you submit while on one of the ADARA Sites. Other than information submitted directly to us by Marketing Partners, we do not collect any PII from consumers by way of our services for our Marketing Partners.

In addition, to the extent permitted by applicable law, we retain the respective sets of information received through the ADARA Partner Sites and through the ADARA Sites for as long as needed to fulfill a legitimate business need. We retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Anyone who has provided PII to us through the ADARA Sites may email us at info@adara.com to request that we update, delete, and/or correct his or her information. We will respond to each such request within 30 days. Even after a deletion, some information may remain temporarily in back-up copies until the next back-up rotation or overwriting cycle.


How to Opt Out

Browser-based opt-out

If you prefer not to receive relevant content from us, you can request to opt out from our services. We will then place a cookie on your browser that identifies you as having opted out.

Additionally, we are a member of the Network Advertising Initiative (NAI) and participate in the Digital Advertising Alliance’s (DAA) Self-Regulatory Program. Each of these programs provides an opt-out feature where consumers can choose not to receive targeted advertising from NAI or DAA affiliates. These links will take you to the NAI opt out and the DAA opt out.

We also participate in the DAA’s Ad Choices program, which enables you to control whether, and if so, to what extent, you receive interest-based advertising. You can exert such control by clicking on the AdChoices Icon on a Web page or near a Web banner ad. To learn more, visit the AdChoices FAQ page.

Remember that opting out is browser-specific. So, if you have multiple browsers or multiple devices you use to access the internet, you’ll need to opt out from each device or browser.

Mobile opt-out

To opt out of interest-based ads where cookie technology may not be available, namely in mobile apps, please follow your mobile device maker’s most current published instructions, such as the examples linked and pasted in below (current as of the date of this version of our Privacy Policy):

  • Android
  1. Open the Google Settings app on your device
  2. Select Ads
  • iOS

Devices with iOS 6 and above use Apple’s Advertising Identifier. To learn more about limiting ad tracking using this identifier, visit the Settings menu on your device as follows:

iOS 7 or higher

Choose Settings > Privacy > Advertising

iOS 6

Choose Settings > General > About > Advertising

In addition, as noted above, we participate in the DAA’s Ad Choices program. So, each of our mobile ads includes the AdChoices Icon, on which you can tap to go to an opt-out page.


Changes to this Privacy Policy

Any information that we collect is subject to the version of this Privacy Policy in effect at the time that information is collected. However, we may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them clearly on our website or by sending you an email or other notification, and we’ll indicate when such changes will become effective.


Other Websites

Our websites contain links to other websites for your convenience. The fact that we link to a particular site does not mean that we endorse that website or its privacy practices. These other websites have their own terms of use and privacy policies, and we would encourage you to read those terms and policies when you visit those websites.


Where We Keep Your Information

Your information may be kept on computers located outside of your state or country, where the privacy laws may not be as protective as those where you live. If you’re located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there. If you reside in the EU or Switzerland, please review the US-EU Safe Harbor section below.


Our Memberships and Affiliations

NAI Membership

ADARA is a member of the Network Advertising Initiative (NAI), a cooperative of companies committed to building responsible advertising policies across the Internet. Using a tool created by the NAI, you can learn more about other ad-serving companies and opt out from their use of cookies.

DAA Membership

ADARA is also a participant in the Digital Advertising Alliance’s (DAA) Self-Regulatory Program for Online Behavioral Advertising and is in compliance with the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. The DAA also provides a global opt-out feature that lets users choose not to receive cookies from companies that are DAA members.

US-EU Safe Harbor

ADARA complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. ADARA has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ADARA’s certification, please visit http://www.export.gov/safeharbor/.

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TRUSTe Certification

ADARA is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build users’ trust and confidence in the Internet by promoting the use of fair information practices. ADARA has agreed to disclose our information practices to, and have our privacy practices reviewed for compliance by, TRUSTe. The TRUSTe program applies only to information collected through the ADARA Sites and through ADARA’s advertising services across third-party desktop websites.

ADARA participates in the EU and Swiss Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above).

If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here, fax to 415-520-3420, or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company.

TRUSTe will then serve as a liaison with us to resolve your concerns. The TRUSTe dispute resolution process shall be conducted in English. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, click here or request that information from TRUSTe at any of the addresses listed above.


Contacting Us

If you have any questions about our Privacy Policy, please email us at privacy@adara.com or send us a letter addressed to:

Chief Privacy Officer
ADARA, Inc.
351 E Evelyn Ave, Suite 100
Mountain View, CA 94041