TapAd

Updated: November 2, 2011

This privacy policy (“Privacy Policy”) describes how Tapad, Inc. (“Tapad”) collects and uses information for its own website and in connection with the services (the “Services”) we provide for its clients. Should you have any questions or concerns regarding our use or collection of information,please send an email to privacy@tapad.com.

Our Principles

1. Provide Notice. Make consumers aware of what information we’re collecting and why.
2. Provide a Clear Opt-Out. Have a clear and identifiable way to opt-out of our tracking and targeted advertising.
3. Ensure Data Security. Provide reasonable security for data we collect and use.
4. Do Not Target Children. Do not deliver targeted ads to children under 13 years old.

1. Provide Notice

In order to provide more relevant ads to users and more targeted ads for advertisers, we collect and store non-personally identifiable information. The technologies we use to collect this information include web and mobile cookies as well as pixels. A cookie is a file on your browser that uniquely identifies your browser and computer. A pixel is a line of code which is used by a website or third party to assign online activities to a computer or browser. The use of a pixel allows websites and us to record, for example, that a user has visited a particular web page or clicked on a particular ad. We use these technologies across platforms including websites, mobile applications, email, and TV applications so that we provide the best cross-platform targeting technology possible. We do not use alternative tracking mechanisms such as HTML5 local storage, “zombie cookies,” history sniffing, and Flash cookies for ad targeting.

The information we collect to target our advertising is not personally identifiable.

What may be collected by Tapad for ad targeting (the Services):

• Time stamp
• User agent string that specifies device and browser information
• IP address
• Network Carrier / Internet Service Provider when applicable
• Hashed unique device identifier when applicable. We hash the identifier upon receipt and immediately dispose of the unique device identifier itself
• Publisher associated with request to place an ad for one of our partners
• Publisher on which advertiser has placed Tapad pixels
• Anonymous data that can be extrapolated from the user’s IP address. For example, we may be able to determine a user’s general location and therefore infer a demographic profile

What is not collected by Tapad for ad targeting:

• Name
• Email address
• Phone number
• Clear text unique device identifiers
• MAC address, or
• Precise GPS location data without an explicit opt-in from the consumer

How is this collected information used:

• Provide targeted advertising to users based on the information collected by Tapad if user has not opted out
• Provide insights and reporting back to advertisers and publishers
• Share aggregate information with advertisers, publishers, business partners, sponsors, and other third parties
• In addition, such information may be used by Tapad for internal analysis in order to perform and improve the Services and associated technologies, and to operate and improve the Tapad Site.

Personal information you explicitly provide to the Tapad websites:

Some of Tapad’s services require user registration or sign-up where we will need Personally Identifiable Information (PII) in order to provide these services. This might include name, postal address, email address, and phone number of our business customers and prospects. We do not sell or rent data collected from our websites, but we may provide it to third-party service providers as necessary to conduct our business operations (like our newsletter) and for the performance of our Services with our customers. We also receive and store non-personally identifiable information from these website visits so that we can better target our own ads for Tapad Services and to analyze our own customer base.

Personal information we collect on behalf of advertisers:

We may collect PII on behalf of advertisers directly from end users. In this case, users are choosing to manually enter this PII as part of their interaction with an advertisement or landing page. Because we are collecting this information on behalf of the advertiser, we may periodically transfer this information to them. This PII collected is not used to target an ad to that individual, and we do not use this information for telemarketing, or sell or rent this information to any third parties for their own use.

2. Provide a Clear Opt-Out

If you would like for Tapad to stop collecting data about your device for targeted advertising, click below to opt-out.

We make best effort to provide a persistent opt-out for online display and, independently, for mobile web. This opt-out must be performed on each device and browser that you want to be opted out on. For example, if you want to opt out on your computer browser as well as your mobile device browser, you will need to click on the link above in both your computer browser as well as your mobile device browser. PLEASE NOTE: Do not just delete cookies from your mobile device. The Tapad opt-out works server side by flagging to Tapad’s servers that a unique ID has opted-out. Thus, if you attempt to opt-out by clearing cookies, or deleting your device’s content cache Tapad will not be able to recognize your device as having opted-out, and if you subsequently visit one of Tapad’s website partners, you may then get a new database or cookie.

The above opt-out will only be enabled if you are accessing it from a Javascript-enabled browser and 3rd party cookies are enabled. These two technologies are required for us to provide a persistent opt-out. Other technologies, such as HTML5 local storage, may also be used in order to make opt-out as persistent as possible.

Please keep in mind that if you opt-out, you will still receive ads, but they will not be tailored to your interests. To opt-out from other companies that Tapad may share information with, or other companies that provide online behavioral advertising services, you can opt-out at the following online advertising industry Websites. The Digital Advertising Alliance Website, www.aboutads.info.

3. Ensure Data Security

Tapad takes steps to protect the security of the information that we collect. To that end, we have designed and deployed hardware, software, and networking solutions in an effort to reasonably secure and protect access to our systems and data.

We do not deliver ads based on individual level data that is more than fourteen (14) months old. We retain the information that we have collected only as long as is legitimately necessary for running our advertising campaigns. We keep opt-out information for longer than this period so that we can continue to honor opt-out requests. Aggregate reports generated from this information may also be kept longer.

4. Do Not Target Children

Tapad is very sensitive to the issue of children’s privacy. We do not target or create audience segments targeted at children under the age of thirteen.

Legal and Other Disclosures

We may share personal information when we believe such action is appropriate to comply with the law (e.g., legal process or a statutory authorization); to enforce or apply our customer agreements; to initiate, render, bill, and collect for Services; to protect our rights or property, or to protect users of those services from fraudulent, abusive, or unlawful use of, or subscription to, such services; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of information without delay.

Change of Control

If we undergo a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of our business, information we have collected may be one of the assets transferred.

Privacy Policy Changes

Tapad may modify this Privacy Policy at any time in its sole discretion. Use of information collected by Tapad now is subject to the Privacy Policy in effect at the time such information is used. Changes to the Privacy Policy shall be announced by posting the updated Privacy Policy on the Tapad Site. Changes to this Policy will be reflected in the “Last Updated” date above.

If you have questions or comments about our Privacy Policy, please contact us at privacy@tapad.com.

This Privacy Policy was last updated on November 2, 2011.