Last Updated October 1st, 2017
Protecting your privacy is very 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 Promise 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 email@example.com, and we’ll be happy to help.
This Privacy Promise covers all 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 Through Marketing Partners’ Websites and Apps
When a user visits one of our Partner’s websites (“Partner Sites”), views an email from a Partner with an ADARA tag, or uses an app with an ADARA SDK installed, we associate a pseudonymous identifier (a random, unique string of characters) with the user, such as through cookies, tags and resettable mobile advertising identifiers or mobile device IDs. A cookie is a small data file that is sent to your computer when you visit a website as an example. Tags (also known as pixel 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 user activity. Mobile device IDs are user-resettable advertising identifiers such as Apple’s IDFA and Google’s Android Advertising ID. 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. Our tags do not collect your name, user name, email address or physical address, but we may store and associate a hashed email address or a mobile device ID with the tag data we collect. Through these identifiers, we can collect information about what the user does on the Partner website or application, and which Partner sites or apps the user visits. ADARA may engage in cross-device data collection and targeting, when the relevant data is collected.
The information we collect may serve to identify a user’s computer or device or browser, and we may associate that information with other data we receive from our Partners and our Partner websites and apps about the user, including the following:
- General data: Partner ID, page type, website name, website language
- Search and booked data: Departure and arrival date, destination country or city, number of travelers, number of days, departure and arrival airport, currency, room rate, payment type, total fare, airline carrier code, hotel brand
- Other data: Hashed email address, mobile device ID, loyalty ID, loyalty tier, which we may use to collect and consolidate information collected about you across different platforms and websites.
ADARA does not use this information to identify you directly. We may also aggregate and anonymize information.
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 information 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 Promise. We may share collected information 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 Promise.
We may share collected information that we receive from our Partners’ websites with the Partner that permitted us to collect the information.
We sometimes make our collected 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 collected information discussed in this privacy promise relating to 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 information such as your name, address, and email address 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 replying to you. We will not use your information for marketing purposes, unless you specifically authorize it. You may opt out of receiving such emails by clicking on the “unsubscribe” link contained in our marketing emails.
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 collected information. We do not permit third parties to collect any information 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.
We do not use any collected information we obtain through cookies to identify you. We do not link the information we store in cookies on ADARA Partner sites to any collected information you submit while on one of the ADARA Sites. ADARA may obtain data from third-parties and combine it with data collected from ADARA Partner sites.
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 information to us through the ADARA websites 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.
To opt-out of the collection and use of data for interest-based advertising on your mobile device, you can modify the settings on your mobile device. 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 Promise):
For Android Devices (version 8.0 and higher): Open the Settings app, Select Google, Select Ads, and enable the “Opt Out of Ads Personalization” setting.
For Apple Devices: 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: Go to Settings, Select Privacy, Select Advertising, and enable the “Limit Ad Tracking” setting. For more information about different iOS versions, please see: https://support.apple.com/en-ie/HT202074.
When you have opted out using this setting on a device, and when Adara receives this signal, Adara will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.
Note: The specific opt-out instructions for each device may differ slightly depending on which version of the operating software you are running.
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 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.
Changes to this Privacy Promise
Any information that we collect is subject to the version of this Privacy Promise in effect at the time that information is collected. However, we may revise this Privacy Promise from time to time. If we make any material changes to this Privacy Promise, 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.
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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 data to us, we may transfer your data to the United States and process it there. If you reside in the EU, please review EU-U.S. Privacy Shield sections below.
Our Memberships and Affiliations
EDAA AND DAA Membership
ADARA is also a participant in the Digital Advertising Alliance’s (DAA) Self-Regulatory Program for Online Behavioral Advertising and follows 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.
ADARA adheres to the Internet Advertising Bureau (“IAB”) Europe’s Good Practise Principals for Online Behavioural Advertising as well as the European Interactive Digital Advertising Alliance’s (“EDAA”) principles.
EU-U.S. 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 or view ADARA’s certification, visit the U.S. Department of Commerce’s Privacy Shield website at [https://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 promise should first contact us at email@example.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 promise and the Privacy Shield Framework, the Privacy Shield Framework shall govern.
If you have any questions or complaints regarding our Privacy Promise or practices, please email us at firstname.lastname@example.org or send us a letter addressed to:
Chief Privacy Officer
1070 E. Meadow Circle
Palo Alto, CA 94303