Your Privacy Rights Summarized by z588ak4


									                ADCONION DIRECT PRIVACY NOTICE
                                                                      LAST MODIFIED [date], 2012

Adconion Direct, Inc. is a proud subsidiary of Adconion Media Inc. You may view their privacy
policy here []. The purpose of this division of Adconion Media Inc. is to help
third parties provide you with relevant advertising on websites and through email marketing
campaigns. We reserve the right to change this Privacy Notice at any time. All changes are
effective when they are posted. We do not retroactively apply any changes that broaden our
rights without notice to you and your consent.

This Privacy Notice explains:

►What information we collect and how;

►How we use and secure that information; and

►The choices we offer you to control collection, use and sharing of information.

What Information We Collect and How
Clients. We collect personal and demographic information from persons and entities who
engage our company’s services when they choose to provide it to us through an application,
contract or request for assistance. Such information may include the business name, individual
contact information, address, telephone number, email address, IP addresses and URL

Consumers. We collect your name, address, telephone number, IP address and email address
from third parties and through our own efforts – e.g., when you register on a website owned or
hosted by us. We also collect behavioral information about you using Cookies, Web Beacons
and Pixels, when you view an ad from one of our advertising clients or visit the website of one
of our publishing clients. This behavioral information includes information about your
computer, your IP address, geographic location, browser preference, operating system type,
websites you have visited, and times that you access the internet.

We do not collect information from children. We do not knowingly collect personally identifiable
information from anyone under the age of 13. If we ever learned that we had inadvertently
collected information from someone under 13, we would delete this information from our
databases as fast as technically possible.

We do not collect sensitive health information. We target advertising for common everyday
health topics such as colds, coughs and heartburn, but we do not collect information about past,
present or potential future medical conditions or treatments.
Consumer Cookies: “Cookies” are a feature in your browser software. The owner of the cookie
can use the cookie to recognize your computer. For example, cookies are the reason your
favorite websites recognize you and remember your preferences each time you visit. We use
tracking cookies to keep track of what you are interested in, so we can do a better job of
connecting you with advertisers who have products and services that interest you.
Our sister company currently uses browser cookies and web beacons to gather anonymous
information when you view an ad (excluding email) from one of our advertising clients or visit
the website of one of our publishing clients, but may also use other technologies in the future.
An Adconion cookie will stay on your computer until you delete it (or until 30 days have gone by
without any online activity). A cookie gives them the anonymous information but it does not
provide your name, your address or any other personal information. Information received
through Adconion cookies are stored on our sister company servers.

Web Beacons: Web beacons are similar to cookies in that they help us recognize your computer
and keep track of your interests and preferences. Web beacons are different than cookies in
that there is nothing that is stored on your computer.

Pixels: Pixels are computer codes that are written into the ads in our emails so that we can track
when an email is opened and when you click on an ad in the email. The only information
collected is your opening and clicking on an ad from one of our emails.

How We Use and Secure the Information

Client Information. We use the information you give us to provide you with services, manage
your account, respond to your inquiries, conduct surveys, tell you about new services, inform
you of important security or product updates, and for other business purposes. We keep
personal information for the duration of your contract and afterward for as long as we think we
may need to reach you.

Behavioral Information. We use this information to tailor our clients’ ads and offers to the
recipient’s interests. Providing Relevant Ads. We use the information we gather for the
purposes of helping our clients marketing their products and services to you. We do not sell or
lease the information provided to us through our list management agreements or that we
gather on our own. We keep third party information for the duration of the agreement and
longer at times to preserve a record for any legal issues. We keep information we have
gathered ourselves indefinitely, although our Cookies themselves expire in 60 days.

Sharing of Information with Affiliated Companies. We share your information throughout the
Adconion group of affiliate companies and our parent company. We also share your
information with vendors who assist us with our business and technical functions, such as
sending email advertising to you. They are contractually bound to maintain confidentiality and
security for the information we provide to them.

Sharing Information with Law Enforcement and for Legal Issues. We follow the laws of the
countries in which we do business. If we receive a subpoena, court order, search warrant or
other legal request that asks or directs us to disclose your personal information, we may comply.
We may also disclose your personal information to law enforcement and others if we believe
you may harm our reputation, our clients, their users or anyone else or commit a crime.

Sharing Information In Connection With Merger or Sale. If we enter into discussions to sell,
merge or otherwise reorganize our business, we reserve the right to transfer and disclose all
data (including personal and anonymous user information) to prospective and/or actual
purchaser or investor(s). We will require that such purchasers/investors treat the transferred
data as described in the privacy policy that exists prior to the change unless and until you
consent to a new privacy policy.


We put a lot of effort into safeguarding your information. We use redundant and robust servers
that are protected by high performance firewalls housed in one of the premium collocation
services in California. Our web frontend and application systems are user and password
protected to prevent access from unauthorized users. Access restriction rules and policies by IP
address and domain are also implemented on our firewalls. Our redundant monitoring systems
notify our IT personnel in the event of downtime and potential threats via email and SMS
messaging. The servers where we store personal information are kept in a secure physical
environment and we have security measures in place to protect against the loss, misuse, and
alteration of personal information under our control. In addition, we currently use Secure Socket
Layer Software ("SSL") to protect data and to secure any transactions. SSL encrypts information,
including credit card numbers, names and addresses, as they are transmitted over the Internet.
However, even with all these precautions, no data transmission over the Internet can be
guaranteed to be 100% secure.
Our technical systems are distributed around the world, so we may store and process your
information on a server that is in a different country than where you live. Some or all of the
information Adconion collects may be stored in the United States and subject to US law.

Control Your Information
You want to change how we collect and use your information, please look at these resources:
         To read more about cookies and how to opt out of Adconion cookies using your
        browser please visit or
        Some of the options at will block or remove cookies during each
        session. If you use the NAI opt out mechanism, then an opt-out cookie is put on your
        computer. That opt-out cookie signals that no tracking cookie should be placed on your
        computer by the companies for which you have opted out. In order for the opt-out to
        work, your browser must be set to accept third-party cookies. If you buy a new
        computer, change browsers, or delete an opt-out cookie, you will need to opt-out again.
        After you opt out, you will still see as many ads as before but they will be less tuned to
        your personal interests.
     Any commercial email you receive from us will include instructions on how to
      unsubscribe from receiving emails from the advertiser in the email and how to
      unsubscribe from the email list. If you unsubscribe from the list, we will remove you
      from that list but we can’t guarantee that the company that provided us with the list will
      remove you from theirs. You can unsubscribe from the email list by contacting us at

Other Companies Who Gather Information
When you visit a website or see an ad, there are many companies who may place cookies on
your computer and gather information about your online behavior: the website publisher, the
advertiser and various other companies that serve ads, analyze user behavior or provide other
services. While we encourage our clients to adopt privacy policies that are consistent with ours,
we do not control any third party’s data gathering practices. The only way to know who is
collecting your information and what they’re doing with it is to read the privacy policies on the
websites you visit and linked to the ads you see.

California Rights
If you are a California resident you have the right to request information regarding the manner
in which we share certain categories of your personal information with third parties. You are
entitled to receive a copy of this information in a standardized format and the information will
not be specific to you individually. Our designated email address for such requests is

Contact Information:

If you have any questions regarding             our   practices,   you   may    contact   us   at:

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