Last Updated September 14, 2016
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
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, devices 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
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
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.
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 firstname.lastname@example.org 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
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.
- Open the Google Settings app on your device
- Select Ads
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
Choose Settings > General > About > Advertising
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 email@example.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 firstname.lastname@example.org. 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.
Social Media Widgets
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
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.
Chief Privacy Officer
351 E Evelyn Ave, Suite 100
Mountain View, CA 94041