NebuAd ISP Advertising Services Privacy Policy: US Version


Effective Date: October 3, 2008

NebuAd, Inc. ("we") is committed to helping its clients reach highly qualified audiences without compromising consumers' privacy. This Privacy Policy applies to the data analytics and audience segmentation services we provide and the advertising we may deliver in connection with commercial relationships with our Internet service provider ("ISPs") partners.

Click here for the NebuAd Advertising Network Privacy Policy, the privacy policy applicable to the data analytics and audience segmentation services we provide and the advertising we may deliver in connection with commercial relationships with our Web Partners. To learn how we collect, use and disclose your personal information when you use www.nebuad.com, please click here.

Information Collection

Our products do not require ISPs to provide us with access to their records regarding end-users' personal information. NebuAd delivers its services without collecting and using personally identifiable information such as the following:

  • Email Addresses
  • Names
  • Street Addresses
  • Telephone Numbers
  • Social Security Numbers ⁄ Social Insurance Numbers
  • Numbers associated with your health plan insurance or other coverage
  • Financial information, including credit card numbers, login IDs, passwords, or bank account numbers

Our products are powered by patent-pending technology that identifies the interests of anonymous subscribers based on their web-surfing behavior.

While we do not know the identity of these subscribers, NebuAd does collect and use the following kinds of anonymous information:

  • Web pages viewed and links clicked on, including advertisements
  • Web search terms
  • The amount of time spent at some websites
  • Response to advertisements
  • System settings, such as the browser used and speed of the connection
  • ZIP code or postal code

We will specifically not store or use any information relating to confidential medical information, racial or ethnic origins, religious beliefs, or sexuality which are tied to personally identifiable information ("sensitive personal information").

Data Transfer

Subscribers from outside of the United States understand that the information we collect is stored and processed on our servers in the United States. As a result, that information may be subject to access requests by governments, courts or law enforcement.

Information Usage

We use non-personally identifiable information that we obtain from our ISP partners to identify appropriate commercial or lifestyle categories of likely interest for our anonymous users in order to target relevant advertisements to these users while they are online.

Opt-Out

Please click here in order to opt-out of NebuAd's information collection and targeted advertisements. Please note that our opt-out mechanism is cookie-based. In order for it to work on your computer, your browser must be set to accept third-party cookies. If you buy a new computer, change web browsers or delete this cookie, you will need to opt out again.

Cookies

We, or our ad network partners, may send one or more cookies (a cookie is a small text file that contains a randomly-generated string of alphanumeric characters) to recognize a user each time the user returns to a site. Cookies are generally used to improve the quality of the user's experience at a website by limiting ad display frequency, storing user preferences, and tracking user trends for purposes of delivering more relevant advertisements.

You can remove cookies by following directions provided in your Internet browser's "help" file. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to enjoy the full functionality of many of the websites you visit.

Log Information

When an end-user visits a particular website, the user's browser may send a variety of information to that website's server and other servers. This information, known as a server log, may include a user's web request, Internet Protocol address, browser type, browser language, and the date and time of the user's request. NebuAd's servers process and store some of this information.

User Communication

We may retain emails or other communications sent to us from users in order to help process inquiries, respond to requests, and improve our general service levels. We do not associate email addresses or other personal information from emails to us with anonymous information we collect.

Information Sharing

While NebuAd does not require or process any end-user personally identifiable information for the purpose of delivering advertisements, our partners may have different privacy practices than our own. We encourage you to read our partners' individual privacy policies.

Occasionally, we may share with third parties certain pieces of aggregated, non-personal information about end-users, such as the number of users who visited a certain website, or how many of them clicked on a particular advertisement. This information does not identify end-users individually.

We sometimes use third party contractors who may be given access to any information we have so they may perform tasks that might otherwise be done by our employees. These contractors, however, have no rights to use such information for purposes other than to perform services for us, and are required to hold such information in strict confidence.

We may also disclose information we have collected when we have a good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:

  • Satisfy any applicable law, regulation, legal process, or governmental request
  • Enforce applicable Terms of Services including investigation of potential violations thereof
  • Detect, prevent, or otherwise address fraud, security, or technical issues
  • Protect against imminent harm to an individual's safety or rights

If NebuAd becomes involved in a merger, acquisition, or any form of sale of a majority or all of its assets, any information we have collected may be one of the assets transferred.

Children

We do not knowingly collect personally identifiable information from, or tailor segments or ads to, children under thirteen years of age.

Information Security

We are committed to protecting all our data from unauthorized access or disclosure. Access to the anonymous information that NebuAd collects is restricted to NebuAd employees, contractors, and agents who require access to that information in order to operate, develop, or improve our services. These individuals are bound by strict confidentiality obligations and may be subject to disciplinary action, including termination and criminal prosecution, if they fail to meet these obligations.

Information Retention

We generally retain non-personally identifiable information for as long as we have a business need to retain it, but typically, for no longer than thirteen months.

Enforcement of and Changes to this Policy

Please note that, while the Policy may change from time to time, we will not reduce end-user rights under this Policy without notifying the user of such changes via a posting on our website. If the changes are significant, we will provide an appropriate online notice. Each version of this Policy will be identified at the top of the page by its effective date.

Please feel free to direct any questions or concerns regarding this Privacy Policy by contacting us directly:

By email at:

[email protected]

Or by writing us at:

Privacy
c/o NebuAd, Inc.
P.O. Box 4880
Foster City, CA 94404

When we receive written complaints at either of these addresses, it is NebuAd's policy to contact the complainant regarding his or her concerns and to work promptly to resolve them to the extent possible.