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; Corporate Websites
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, without limitation, 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 or application; and tracking the number of ads served on a particular day to a particular website or application. To do so, we collect certain technical information about an end user when they interact with our services including the type of device, browser, mobile application and operating system used including the particular version or model and certain configurations and settings, non-precise geographical location (through IP addresses and regional data), device identifiers such as IDFA for IOS and the Advertising ID for Android, ISP (Internet Service Provider) and ISP location, as well as the domain name or details of the application, day and time of visit, and page(s) visited. We do so across multiple web domains and applications owned or operated by different entities within the Undertone Site Network.
Undertone may also collect this information when you are visiting the Undertone corporate site.
Data to Serve Relevant Advertising
We want to deliver more relevant advertising to you. Delivering more relevant advertising to you and other visitors allows owners of website and applications 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 the Undertone Site Network to categorize likely consumer interest segments for use in advertising online (“Interest-Based Advertising” or “IBA”) such as the web pages you visit or applications you use, the content you see, access and utilize on such web pages and applications; for example, offerings and advertisements that you view, use and access, how you use them and your response to them (ie. clickstream data), how frequently and when you use them. 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 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, our advertising partners and certain technology vendors, collect the information described above by using log files, pixels or 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.
- “Pixels” or “Web beacons” are electronic files or tags that reside on web pages and applications and are used to track your navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior.
In addition to the uses set forth below, our primary use of the information we collect is 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
In certain circumstances, Undertone, or Advertisers, may collect personally identifiable information, which is any information that identifies you or can be used to identify you (PII), including but not limited to, your name, telephone number, address, email address, and date of birth, but only if you choose to provide it to us. These circumstances can include as part of an advertising campaign (eg. through online forms on advertisements and which will not be used for IBA) or through 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. Such information will only be used to provide you with support services and contact you in connection with the services we provide.
Information Obtained from Other Companies
Using and Sharing Your Information
We also may share information with advertisers, publishers and other third parties for marketing and advertising purposes, but such information does not include PII (but may include certain personal data such as IP address, device identifiers and other online identifiers) except if you actively provided it in connection with an advertisement.
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, Undertone will no longer be able to recognize your browser for the purpose of IBA. 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.
In the mobile environment, if you reset your device ID on your device, Undertone will no longer be able to recognize your device for the purpose of IBA.
Undertone retains information regarding ad delivery (see, “Ad Delivery & Reporting” above) for up to fourteen (14) 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 on the web. 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 on the web through “ads.undertone.com” as well as “legolas-media.com.” You may also opt-out of web 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.
Please report any problems related to the opt-out process to firstname.lastname@example.org.
Undertone is also committed to providing customers the ability to opt-out of IBA in the mobile setting. For mobile opt-outs, we rely on the standard opt-out mechanism for ad traffic that we get from mobile applications. Users may choose not to be tracked for advertising purposes by accessing their mobile device’s privacy settings. When Undertone receives an in-app ad request from an in-app advertising partner, it also receives a “DNT” (do not track) indication in the ad request. The value for the DNT parameter is captured from the user’s privacy settings. When Undertone receives a DNT=1, we honor this as an opt-out request.
Undertone adheres to the Interactive Advertising Bureau Europe’s OBA Framework and participates in the European Interactive Digital Advertising Alliance’s (EDAA) 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 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.
In all such cases, we may require that you provide us with additional information to verify your identity and any third party recipients of your PII based on your written request.
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.
Transfer of Data Outside Your Territory
The services we provide are provided over the Internet and we may store and process information in various locations throughout the globe. If you are a resident of a jurisdiction where transfer of your personal data to another jurisdiction requires your consent, then you hereby provide us with your express consent to such transfer of your data.
Notice To Californian Residents – Your California Privacy Rights
California residents who provide us with certain types of personal information (as defined under California Civil Code Section 1798.83 (also known as California’s “Shine the Light” law)) are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing use. To make such a request, please contact us through the email or physical address under the “Complaints; Contact Us” section below.
When making such a request, please ensure that you write in the subject line and the body of your message “Request for California Privacy Information”.
Please be aware that not all information sharing is covered by California’s “Shine the Light” law.
Do Not Track
Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature”); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Undertone does not currently respond or recognize DNT Feature signals.
Complaints; Contact Us
Intercept Interactive, Inc. d.b.a. Undertone
Attn: Chief Compliance Officer
340 Madison Avenue
New York, NY 10173