The terms “you,” “your,” and “yours” refer to the website visitor or consumer. The terms “Undertone,” “we,” “us,” and “our” refer to Undertone, and the companies under its control (such as subsidiaries), or under common control (such as parent companies, or companies owned by its parent company) (collectively, “Undertone Entities”).
Information We Collect
Ad Delivery & Reporting Across Multiple Sites
As part of our ad delivery and reporting, we log page views and collect information for the purpose of delivering ads or providing advertising-related services, including providing a specific advertisement based on a particular type of browser or time of day; statistical reporting in connection with the activity on a website; and tracking the number of ads served on a particular day to a particular website. To do so, we collect information about the type of browser and operating system of website visitors, as well as the domain name, day and time of visit, and page(s) visited. We do so across multiple web domains owned or operated by different entities (each, a “Site”).
We want to deliver more relevant advertising to you. Delivering more relevant advertising to you and other website visitors allows website owners to generate more advertising revenue. This revenue pays for the free content that they may publish for you, or free services that they may deliver to you. It also means that you are more likely to see online advertising that meets your interests.
In an effort to deliver relevant advertising to you, we collect data across multiple web domains owned or operated by different entities to categorize likely consumer interest segments for use in advertising online (“Interest-Based Advertising” or “IBA”). For example, we can analyze data to determine that a visitor of a particular site at 6:30PM is more likely to be interested in pizza, or antique cars, or a classic movie. We can then serve an ad to the web page the visitor is viewing that offers a discounted pizza, car show tickets, or classic movie DVD—importantly—without ever knowing the identity or personal information of the visitor.
If you do not wish to benefit from relevant advertising, please feel free opt out IBA as described in the paragraph titled “IBA _Opt-Out”, below.
We collect the information described above by using log files, web beacons and cookies. We often engage or cooperate with service and technology companies to collect this information. While this tracking and collection technology is commonly used, you might not be familiar with it, and we would like to explain it:
- -“Log files” track actions occurring on websites and collect data including your IP address, browser type, Internet service provider, referring/exit pages, platform type, date/time stamp, click data and types of advertisements viewed.
- -“Web beacons” are electronic files used to track your navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior.
We use the information we collect for marketing and advertising purposes, to determine which ads perform well, to better match ads and website content to your interests, to assist us in improving the operation of our services, to maintain the quality of our services, to enhance our services to our business partners and clients, to provide general statistics to our business partners and clients regarding use of Undertone’s services, and for the other purposes described below.
Personally Identifiable Information
Undertone does not collect or use Personally Identifiable Information (PII) for IBA. PII is any information that identifies you or can be used to identify you. This includes, but is not limited to, your name, telephone number, address, email address, and date of birth. Undertone does not collect PII unless you choose to provide it to us. You may choose to do so as part of your interaction with Customer Forms on the Undertone corporate site.
Examples of such Customer Forms include, but are not limited to: registration forms to access Undertone published white papers or Undertone produced webinars, and forms providing customer contact information when requesting information from Undertone.
Non-Personally Identifiable Information
Non-Personally Identifiable Information or Non-PII is data that is linked or reasonably linkable to a particular computer or device, but is not PII, including, but not limited to: your IP address, web pages which you have viewed, and your responses to internet advertisements. This information may be collected using different types of internet technologies, such as cookies (see, “Internet Technology” above for more details).
Undertone may collect this information when you are visiting the Undertone corporate site or any website within the Undertone Site Network. However, this information is not combined with PII.
Information Obtained from Other Companies
Sharing Your Information
In the event that Undertone is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.
Information Collected by Third Party Sites
Your Internet browser stores IBA-related data as cookies. If you have cookies disabled, if you delete your cookies, or if other software deletes the cookies used for that data storage, such data is lost because it is not retained separately by Undertone. The cookies that store data related to Undertone’s IBA will in any case expire, at latest, one year after the last time such information is stored, barring any technical malfunction.
Undertone retains information regarding ad delivery (see, “Ad Delivery & Reporting” above) for up to six (6) months. However, Undertone may retain aggregate statistics, reports and summaries regarding ad delivery for a longer period.
Undertone is committed to providing consumers notice and choice regarding IBA. Undertone offers an “opt-out cookie” for those that wish to opt-out of Undertone IBA activities. This cookie will honor your IBA preferences for a period of five (5) years. We may increase this period, which means your opt-out choice will continue for a longer period. If you have multiple Internet browsers or users on the same computer, you will need to perform the opt-out operation for each browser and/or user. If you or your anti-virus or other software deletes the opt-out cookies from your computer, if you re-install your browser, or if you delete your cookies (which can happen if you clear or delete your browser history), then you will need to repeat the process. Undertone may be unable to provide you with an opt-out cookie if your browser is set to block third-party cookies.
To opt-out of IBA, please use our opt-out tool.
Please note that the above opt-out link is applicable to Undertone IBA activities conducted through “ads.undertone.com” as well as “legolas-media.com.” You may also opt-out of IBA conducted by Undertone and other member companies of the Network Advertising Initiative (NAI) by visiting the NAI website here. Or you may opt-out of IBA by Undertone and other member companies of the Digital Advertising Alliance (DAA) by visiting the DAA website here.
For Canadian consumers, you may also access the opt-out tool on the Digital Advertising Alliance of Canada (DAAC) website here.
Please report any problems related to the opt-out process to firstname.lastname@example.org.
Undertone adheres to the Interactive Advertising Bureau Europe’s OBA Framework and participates in the European Interactive Digital Advertising Alliance’s self-regulatory initiative. Accordingly, in addition to the opt-out options above, users can learn more about IBA and opt-out through the industry page www.youronlinechoices.eu. Further, Undertone does not collect or use for the purpose of IBA, data that is considered personal data or sensitive personal data under the respective national implementations of the EU Directive 95/46/EC.
Undertone is very sensitive to the issue of children’s privacy. Some of Undertone’s products and services are developed for, or directed to children. However, Undertone does not collect, use, or disclose personal information from children under 13, as that is defined by the FTC under the Children’s Online Privacy Protection Act (COPPA), and Undertone is fully compliant with COPPA. If you believe your child has provided us with PII through the Undertone corporate site or through our corporate marketing materials, please contact us and we will delete any such data.
User Choice and Privacy Generally
Undertone is a member of the Network Advertising Initiative (“NAI”) and adheres to the NAI’s Code of Conduct. The NAI is a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards. For more information, please visit www.networkadvertising.org.
AdChoices: Undertone supports deployment of AdChoices icon, in partnership with Ghostery Enterprise, as part of its compliance with Digital Advertising Alliance self-regulation program. As part of this service, online advertisements served by Undertone are sometimes delivered with icons that help consumers understand how their data is being used and provide choice options to consumers that want more control.
Undertone employs standard measures to ensure the security of all information. We routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume these risks when communicating with us.
Attn: Chief Compliance Officer
340 Madison Avenue
New York, NY 10173