Privacy Commitment

Last Updated September 14, 2016

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 regarding use, access and correction of your personal information. 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 or analytics 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 analytics services for the benefit of our business customers, giving them the ability to reach and understand 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 (“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. We do not collect 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. Different countries have different definition of what constitutes PII, so this information may be considered PII in some countries. ADARA does not use this information to identify you individually or personally. We may also aggregate and anonymize information. 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 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 Partners to determine what advertisements or other personalized content might be interesting to you. For example, if any pseudonymous identifier indicated a recently purchased ticket to New York City on a website run by one of our Partners, we may predict that the identifier might belong to a person interested in seeing advertisements about Broadway plays. We also use the information to create analytics around industry trends or the effectiveness of media and content marketing. For example, we may provide analytics on travel searching and booking patterns for New York City.


How Information Is Shared

ADARA will only share information with third parties in ways that are described in this Privacy Policy. 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 information that we receive from our Partners’ websites with the 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

When you visit our website, we and our third party service providers may use cookies and other technologies to understand the usage of our website, perform analytics, provide functionality, track user movement across our websites and gather demographic information about our user base as a whole; we may use this information or provide it to a third party partner to provide you with relevant display advertising on our website or other websites. Users can control the use of cookies at the individual browser level. If you change your setting or reject cookies the use of some features or areas of our website may become limited.

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 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, create industry analytics and personalize your experience on ADARA 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 any information we obtain through cookies to identify you. We do not link the information we store in cookies on ADARA Partner sites to any PII you submit while on one of the ADARA Sites. Other than information submitted directly to us by Partners, we do not collect any PII from consumers by way of our services for our 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 a reasonable time. 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 or interest-based advertising from us or participate in any analytics tracking, 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 reset your mobile advertising ID or to opt out of interest-based ads 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.


Access and Choice

​As required by applicable law, including the U.S.-E.U. Privacy Shield Framework, upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. You may request this information by emailing us at privacy@adara.com. If you are our partner or customer and your information changes, or if you no longer desire our service, you may correct, update, amend or remove information by contacting us at privacy@adara.com. We will respond to these requests within a reasonable timeframe. If you use our Self-Serve Platform, you may access and update your information by logging into your account.

Our use of information collected through our service shall be limited to the purpose of providing the marketing or analytics services for which our Partner has engaged ADARA. ADARA collects and processes information under the direction of its Partners, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Partners and would no longer like to be contacted by one of our Partners that use our service, please contact the Partner that you interact with directly.


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 if we have your contact information, 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.


Social Media Widgets

​Our websites may include Social Media Features. These button(s) or interactive mini-programs run on our websites. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social Media features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing the service.


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, please review the EU-U.S. Privacy Shield sections 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 and adheres to the Network Advertising Initiative Standards (NAI Code of Conduct and Mobile Application Code). 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 Privacy Shield

ADARA (which shall include entities and subsidiaries covered by ADARA’s privacy shield certification) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. ADARA has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website at www.privacyshield.gov/welcome. To see a list of participating companies in Privacy Shield please refer to the following website: www.privacyshield.gov/list.

ADARA is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. ADARA complies with the Privacy Shield Principles for all onward transfers of personal data from the EU. ADARA remains liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such personal data on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, ADARA is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ADARA may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-US Privacy Shield Principles, ADARA commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact us at privacy@adara.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Framework, the Privacy Shield Framework shall govern.


Contacting Us

If you have any questions about our Privacy Policy or practices, 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