(Postcards only, please)
Attn: Privacy Department
818 W. 7th Street, Suite 700
Los Angeles, CA 90017
Effective Date: July 31, 2012
INTERPOLLS PRODUCTS AND SERVICES OVERVIEW
Interpolls creates, develops, and licenses our proprietary digital ad-serving technologies and patented dynamic creative optimization advertisements, dynamic personalization advertisements, dynamic content feeds advertisements, interactive video advertisements, rich media advertisements, mobile rich media advertisements, online behavioral targeting advertisements, interactive marketing, promotions (including without limitation sweepstakes, contests and giveaways administered and/or hosted by Interpolls for its clients), social media products, emerging media products, and other custom solutions and related services ("Products and Services") delivered and managed by the Interpolls technology platform (the "Platform"). Interpolls provides the Products and Services and Platform for advertisers and their advertising agencies (collectively "Clients") that are in the business of marketing their products or services to users on Third Party Web Sites, ad networks, ad exchanges, or other technology and data providers (collectively "Affiliates").
THE COLLECTION AND USE OF USER INFORMATION
Personally Identifiable Information
Personally Identifiable Information ("PII") is individually identifiable information about a particular individual that permits the physical or online contacting of such individual. Examples of PII include (without limitation):
Please note: PII is only collected by us in connection with our Website, Products, Services, and Platform where users voluntarily submits such PII.
- first name, last name
- physical mailing address
- home or business address
- telephone number (home, business, and/or mobile/cellular)
- e-mail address(es)
- approximate age/birth date (month/year)
For our Website, PII is only collected when a user submits a specific request for information or requests to be contacted by us through our Website submission form, or sends certain e-mail communications to us, including without limitation customer queries, requests for customer support or copyright infringement or DMCA notices. Our use of this PII is solely to respond or otherwise address the e-mail communication from the user. We do not collect this PII for any other purpose and do not merge it with other PII or Non-PII (as defined below).
For certain advertising Products and Services and at the request and on behalf of a Client, Interpolls collects information supplied voluntarily by a user's submission which may include PII (e.g. User's name, email, etc.) through form fields filled by the user within our advertising Products delivered and displayed by our Platform on Third Party Websites. Following the collection by us or at the conclusion of the Client campaign, this PII is securely encrypted and delivers this PII only to the Client on whose behalf the information was collected. Interpolls does not re-use, re-sell, or distribute this PII to any other party and destroys this PII upon confirmation of delivery from the Client. The Clients' use of the PII is governed by and subject to their own privacy policies. Interpolls is not responsible for the Client or Third Party Websites' use of this voluntarily supplied data.
Non-Personally Identifiable Information
We collect and use Non-Personally Identifiable Information ("Non-PII"), which is any information other than PII and does not identify the specific individual. Non-PII includes without limitation: IP address, the approximate geographic location of the User based on their IP address the type of browser and operating system used by the User, the number of ad units delivered to each website(s), the date and time the ad unit was delivered, any interactions a User may initiate within the ad unit, the websites and web pages that users visit or visited, the type of Product delivered by us that users view on websites they visit, user interactions with features, content preferences user interact within ad units, and other inferences about the user's interests made based upon the foregoing. This Non-PII is aggregated by our Platform and does not personally identify any single user. The aggregated Non-PII by our Platform is used to provide reporting metrics for our Clients and Affiliates.
Users may be assigned a "persistent cookie" on their web browser that will identify the user by assigning a randomly generated, unique ID that any of our Products and/or Technology will be able to recognize the user (but not your actual identity). This randomly generated anonymous ID is not merged with any PII of the user and our cookie does not collect any PII. Our web beacons may be placed on our Clients and Affiliates website(s) which you may visit or interact with any of our Products that will recognize our cookie set in your web browser. This cookie in connection with our Platform will record and store the Non-PII of the user as defined above, including without limitation the user's IP address, the specific type of web browser and operating system used by the user, the date and time our Products and Services was delivered, the websites and web pages that user visit or visited, the user's online behavior, regardless of whether those websites or web pages belong to our Clients or Affiliates.
We use the Non-PII collected by our Platform, which may be combined with other data from our Technology Partners to help make ads served and displayed more relevant to users on behalf of our Clients through the use of our cookies and to deliver subsequent ads specific to interests expressed by the user information on specified dates, times, or websites as defined by our Clients, Affiliates or Technology Partners. Our Platform will also use portions and/or all Non-PII collected for reporting purposes for our Clients. The Platform may deploy web beacons and cookies on User's web browsers and web sites to collect information to apply that and other user data provided by our Technology Partners to deliver more relevant Client advertisements through our Platform and provide the best user experience and improve our Clients advertising results. Interpolls will not combine any Non-PII data internally or data from our Technology Partners that would identify an individual or a user's PII. Interpolls does not share Non-PII with non-related third parties unless required by law, including without limitation for the investigation of illegal activity.
Cookies and Web Beacons
As described below, users also have the option to utilize an Opt-out cookie placed on the specific web browser to prevent our Website, web beacons, Products and Services and Platform from tracking and collecting user information by us. Please note that disabling cookies on the browser does not mean Users will no longer receive online advertisements from us. It means that Interpolls will no longer be able to deliver advertisements to that User that are tailored to his or her preferences or to limit the number of times the User see the same advertisement.
If Users would like to opt-out from having Interpolls collect user information and track online behavior in connection with our Website, Products and Services, and Platform, please click here to opt out. When a user opts out, we will place an opt-out cookie on that user's specific web browser (i.e. Internet Explorer, Firefox, Safari, etc.). The opt-out cookie tells us not to collect user information and not to tailor our Website, Products and Services and Platform to the user's interests. Please note that if you delete, block or otherwise restrict cookies, or if you use a different web browser on the same computer or use a different computer, you may need to renew your opt-out choice. The opt-out cookie does not mean you will no longer receive online advertisements from us. It means that Interpolls will no longer be able to deliver advertisements to you that are tailored to your preferences or able to limit the number of times you may see the same advertisement.
DISCLOSURE OF INFORMATION TO THIRD PARTIES
When you voluntarily provide PII to complete registrations, enter promotions, contests or sweepstakes, or request products or services information from Clients and Third Party Websites, you are consenting to share the PII with Clients and their Affiliates so they can fulfill your request. Except in those instances where you voluntarily provide PII in connection with our Website or Products and Services to Client and Third Party Websites, we do not sell, rent or share PII collected on our Website with non-affiliated third parties without your consent. We may, however, share your PII with trusted third party contractors who provide services for us. These third party contractors are prohibited from using the information we provide for purposes other than performing services for us.
We may share Non-PII collected via our Products and Services or Platform with our Clients. Similarly, we may enhance the Non-PII collected via our Technology with Non-PII collected from our business partners. This information cannot be used to contact or identify any person individually.
User Information (PII and Non-PII) may also be disclosed by us in the following circumstances:
- To respond to a subpoena, court order or other legal procedure; or
- To investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person or to prevent financial loss to any person or entity
LINKS TO OTHER WEBSITES
CHILDREN'S PRIVACY STATEMENT
Special Note about Children: This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of 13, and provides important information regarding their rights under federal law with respect to such information.
CALIFORNIA RESIDENTS PRIVACY RIGHTS
- Our Website is not intended for or directed to Users under the age of 13. Any user of our Website expressly represents and warrants that they are 13 years of age or older. Unless otherwise specifically indicated, Interpolls does not intentionally collect or store PII or Non-PII from users under the age of thirteen (13).
- On certain occasions, Interpolls may administer some promotions or sweepstakes on behalf of its clients, which collect PII from children under the age of thirteen (13). In each such instance, Interpolls shall comply with the Children's Online Privacy Protection Act ("COPPA"), in the process of such promotion or sweepstakes, the collection of the information and in the subsequent use of the data collected. PII will not be collected from children under the age of thirteen (13) without parental consent in compliance with the COPPA guidelines.
Your California Privacy Rights, as provided by California Civil Code Section 1798.83, California residents who have provided personal information to a business, are entitled to request information whether the business disclosed personal information (if any) to third parties for direct marketing purposes. In general, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which the business disclosed and shared information in the preceding calendar year.
If you are a California resident and would like to make such a request, please submit a written request to:
c/o Privacy Department
818 W. 7th Street, Suite 700
Los Angeles, CA 90017
Our Website, Products and Services and Platform are all hosted in the United States. If you are accessing our Website, Products and Services and Platform from the European Union, Australia, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please note that you are transferring your personal data to the United States which does not have the same data protection laws as such other regions. User Information collected on the Interpolls Website, Products and Services, and Platform may be stored and processed in the United States, and by using our Website, you consent to any such transfer of information outside of your home country.
Interpolls uses industry standard security measures to protect the loss, misuse and alteration of the information from unauthorized access, use, modification, destruction, or disclosure. This includes, but is not limited to the use of firewalls and encryption. Nonetheless, due to the inherent dangers of the Internet, no data transmission over the Internet cannot be guaranteed 100% secure by Interpolls. Interpolls does not and cannot guarantee or warrant the protection and security of any user information against loss, misuse or alteration that users transmits on or through the Internet to our Website, Products and Services, or Platform, and users are hereby notified that this is done at the user's own risk.
Password-protected areas of the Interpolls Website can be accessed only with a valid user name and password. Each password owner is responsible for keeping the password confidential and safe, as Interpolls has no control or responsibility for this type of user Information. If the password may have been stolen or might otherwise be misused, it is the responsibility of the password owner to notify Interpolls immediately for further action.
c/o Privacy Department
818 W. 7th Street, Suite 700
Los Angeles, CA 90017