Adara Privacy Policy
Updated 9/15/12
Adara Media takes your privacy seriously. In this regard, Adara Media has established the policies and procedures set forth below regarding the collection, use and disclosure of information we may receive directly from you and other visitors to the Adara Media web site, http://www.adaramedia.com (the "Site"), information we may receive from those businesses we provide services to ("Marketing Partners"), and information we may obtain from the use of "cookies" (as defined below). This policy applies to the collection, use and disclosure of information by Adara Media and the use and disclosure of consumer information we receive from our Marketing Partners. The collection of information by our Marketing Partners and their use and disclosure of such information is subject to their individual privacy policies.
Adara Media is a member of the Network Advertising Initiative (NAI) and is in compliance with the NAI's Self-Regulatory Principles. Among other things, the NAI allows for the central control of all of its members' cookies from a single "opt-out" page. Please see the "Opt-out" section of this policy below for more information about the NAI "opt-out" page.
Adara Media is 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 provides a central "opt-out" page where consumers can exercise choice. Please see the "Opt-out" section of this policy below for more information about the DAA "opt-out" page.
Adara Media is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build user's trust and confidence in the Internet by promoting the use of fair information practices. As a licensee of the TRUSTe Privacy Program we have agreed to disclose our information practices to, and have our privacy practices reviewed for compliance by, TRUSTe.
Adara Media complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union
If you have questions or concerns regarding this Policy, you should first contact privacy@adaramedia.com. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://watchdog.truste.com/pvr.php?page=complaint&url, by mail at WatchDog Complaints, TRUSTe, 55 Second Street, 2nd Floor, San Francisco, CA 94105, by phone at 415-520-3400, or by fax at 415-520-3420. If you are 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. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://watchdog.truste.com/pvr.php?page=complaint&url or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. TRUSTe will then serve as a liaison with us to resolve your concerns.
Definition of Terms
Personally Identifiable Information ("PII")
PII means your name, home and work address, telephone number, URL, email address and any other information that identifies you personally.
Non-Personally Identifiable Information
Non-Personally Identifiable Information means information that does not identify you personally. This information is anonymous, i.e. it does not identify you personally, and only includes information such as your computer's Internet Protocol ("IP") address, browser type, and activity on our Marketing Partners' websites. Non-Personally Identifiable Information may be collected by both Adara Media and its Marketing Partners.
Sensitive Information
We do not knowingly collect or utilize Sensitive Information. Sensitive Information may include information such as confidential medical information, racial or ethnic origins, political or religious beliefs and other similar or related information.
Services
"Services" means the information analysis and advertising services offered by Adara Media to its Marketing Partners. Adara Media collects and analysis Non-Personally Identifiable Information about consumers in order to enhance overall consumer experience by improving the delivery of relevant online advertising to individual consumers.
Cookies Like many websites, we use "cookies" to collect information. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. We use cookies to personalize your experience on our Site and to keep track of advertisements we believe are relevant to you. 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. We do not use cookies to obtain PII. We do not link the information we store in cookies to any PII you submit while on our Site.
In addition to Adara Media cookies, we may transfer Marketing Partner or other third party cookies to you to make it easier for you to navigate and make full use of our Site and the websites of said Marketing Partners and other third parties. Other than transferring Marketing Partner and other third party cookies to you when requested to do so Adara Media has no access to or control over these cookies. Adara Media uses a third-party tracking service that uses cookies, web beacons and log files to track Non-Personally Identifiable Information such as visitor traffic patterns on our site in the aggregate. We analyze this information to understand how many people visit our site in aggregate. This privacy statement covers the use of cookies by http://www.adaramedia.com only and does not cover the use of cookies by Marketing Partners or other third parties.
If you do not want to receive cookies you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, you may not be able to use all portions of our Site or the functions of the Services (as further described below) we offer.
Information Collection and Use
Adara Media is in the business of providing Services to its Marketing Partners. When collecting consumer information through the use of Cookies or obtaining consumer information from our Marketing Partners we do not attempt to collect PII, nor do we deliver ads to consumers based upon PII. We only collect, analyze and use Non-Personally Identifiable Information for the purposes of providing Services to our Marketing Partners.
If you contact us and in doing so provide us with PII such as your email address, name, home or work address or telephone number, we will store that information in our database and will use that information only for the purpose of replying to you and not for analysis or advertising delivery purposes, unless you specifically authorize the use of your PII for other purposes. We do not share, sell, rent or trade any of your PII to any third party for promotional purposes or otherwise.
Adara Media may work with Marketing Partners who's Privacy Policy allows them to share Non-Personally Identifiable Information about their customers and/or inquirers, such as demographic data, consumer interests, participation levels, purchase behavior and/or user-generated content. As stated above, Adara Media does not receive PII from, or provide PII to, its Marketing Partners. The Non-Personally Identifiable Information received by Adara Media allows us to analyze and understand more about Marketing Partners' customers and what they might be interested in. This analysis allows Adara Media to target and deliver more relevant advertisements to these customers as they surf the Internet, benefiting both the customer and the advertiser.
We keep all information that we receive from our Marketing Partners strictly confidential. This information is stored in a secured database. We store information in our secured databases for the purposes of providing Services for no more than two years from our receipt of the information. We do not permit access to the information contained in our database, except as specifically directed by our Marketing Partners or as may otherwise be required by law.
Information Sharing and Disclosure
Aggregate Information and Non-Identifying Information
We may share with our Marketing Partners and others aggregated information that does not contain PII and does not identify you personally. We may also disclose Non-Personally Identifying Information to others for industry analysis, demographic profiling and to deliver targeted advertising about other products and services.
Service Providers
We may employ third parties to facilitate our Services, provide Services on our behalf, perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site's features) or to assist us in analyzing how our Site and Services are used.
Compliance with Laws and Law Enforcement
Adara Media complies with those laws that protect the privacy and security of information. We reserve the right to release information to local, state, or federal law enforcement officials when we believe in good faith that the law requires it, or when required to do so by order of a Court or authorized administrative agency. We further reserve the right to disclose information, which may include PII, to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims or legal process, to protect the property and rights of Adara Media or a third party, to protect the safety of the public or any person, or to prevent activity we may consider to be illegal or legally actionable.
“Opt-out” Procedure – Changing or Deleting Your Information
You may Opt-Out of Adara Media's Services and Site at any time. If you prefer not to receive relevant advertising from us, simply click on the following link to Opt-Out. Anyone who has provided PII to us through our Site may email us atinfo@adaramedia.com to update, delete, and/or correct their information. We will respond to your request to access within 30 days.
Additionally, Adara Media is a member of the Network Advertising Initiative (NAI) and participates in the Digital Advertising Alliance’s (DAA) Self-Regulatory Program for Online Behavioral Advertising. Each of these programs provides an opt-out page where consumers can exercise control over members’/participants’ cookies from a central location. To find out more and opt-out of NAI members’ or DAA participants’ cookies, visit:
• NAI: http://www.networkadvertising.org/managing/opt_out.asp
• DAA: http://www.aboutads.info/choices/
Please note that when you Opt-Out we still need to maintain a cookie on your computer in order to recognize that you've opted out. You must Opt-Out in this same manner again if you want to clear that cookie from your browser, or you can use a different Internet browser or different computer to access the Internet.
Security
Adara Media 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. However, in some instances our Marketing Partners or others may provide information to us in un-encrypted form. In the unlikely event of a breach of our security measures if your unencrypted electronically stored "personal data" (as that term is defined in applicable state statutes) is obtained by a third party not authorized to view such information, and we are required by law to provide you with notification of such unauthorized viewing, then we will notify you via email or a conspicuous posting on our Site without unreasonable delay. We will take immediate steps to determine the scope of the breach and restore the security measures to our system.
Links to Other Sites
Our Site contains links to other websites and our Services operate via our Marketing Partners' websites. If you choose to visit an advertiser by clicking on a banner ad or other type of advertisement, or click on a third party link, you will be directed to that third party's website. The fact that we may link to a website operate by a Marketing Partner or other party, or present a banner ad or other type of advertisement on our Site, is not an endorsement of that party by Adara Media, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites may follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
Privacy of Children
Adara Media is committed to protecting the privacy of children. Neither Adara Media's Site nor its Services are intended or designed to attract children under 18. In addition, we do not knowingly collect any information, PII or Non-Personally Identifiable Information, from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with PII without their consent, he or she should contact us at privacy@adaramedia.com as soon as possible. If we become aware that a child under 13 has provided us with PII, we will delete such information from our files and take such other action as may be required by law.
Changes to this Privacy Policy
This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site, by email or by means of a notice on our home page. We recommend that you visit our Site periodically to review our Privacy Policy for any changes.
Contacting Us
If you have any questions about this Privacy Policy, please contact us at privacy@adaramedia.com or at:
Chief Privacy Officer
Adara Media, Inc.
444 Castro St, Suite 130
Mountain View, CA 94041
