NebuAd Advertising Network Privacy Policy: US Version

Effective Date: October 3, 2008

NebuAd, Inc. ("we") is committed to helping website owners, advertisers, and their representatives (collectively, "Web Partners") 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 Web Partners.

Click here for 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 Internet service provider partners. To learn how we collect, use and disclose your personal information when you use www.nebuad.com, please click here.

Overview of NebuAd Services

We and our Web Partners use anonymous information based on web users' online activities (as described under "Information Collection" below), to help make the content on websites you visit or ads you see more relevant to you. We also provide our Web Partners and other customers with anonymous data analytics (the types of things web users do on the sites of our Web Partners, such as visiting certain web pages or clicking on certain advertisements) and audience segmentation services (the appropriate commercial or lifestyle categories of likely interest for our anonymous web users based on the types of things web users do on the sites of our Web Partners, such as visiting certain web pages or clicking on certain advertisements).

We do not retain the original raw data about web users' online activities, such as websites visited, linked to an identifiable individual. Nor do we provide analytics or segmentation services regarding adult or sexual topics, sensitive medical information, racial or ethnic origins, religious beliefs, child-oriented subjects, or illegal products. In addition, neither we nor our third party technology vendors deliver any content or advertisements based on these subjects, and there is no information collected on these subjects.

Information Collection

When you visit, over time, one or more of our Web Partners' websites (or advertisements), we or our third party technology vendors collect and analyze the following anonymous information:

Web pages viewed and links clicked on, including advertisements
Web search terms
Web pages that referred you to the Web Partner's page, as well as the page you go to when you exit the Web Partner's site
Response to advertisements
System settings, such as the browser used
The date, time and domain type of your visits to our Web Partner's website(s)

Third party technology vendors acting on our behalf may also collect your IP address, to determine your actual or approximate 5-digit zip code, and then your IP address is immediately discarded.

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").

To collect the non-personally identifiable information described above, we, our third party technology vendors, and our Web Partners use cookies and web beacons. A "cookie" is a small text file that contains a randomly-generated string of alphanumeric characters. Web beacons are small strings of code that recognize our cookie on your computer when you view or act upon a Web Partner's page or link. Web beacons also allow us to record that someone has visited a particular page. We and our third party technology vendors use them together with cookies to analyze usage patterns. This technology also assists us with various other tasks, such as controlling the number of times you are presented with one of our Web Partners' 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.

Data Transfer

Web users 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 the non-personally identifiable information that we or our third party technology vendors collect to infer the appropriate commercial or lifestyle categories of likely interest for our anonymous web users. We call this "segmentation." The segmentation does not contain any original raw data, such as websites visited, but consists only of a set of numbers that represent anonymous inferences about the user's level of qualification for a predefined set of interest segments (for example, football, cooking, or travel). We, or our Web Partners, use this information to help make the content on websites you visit and the ads you see more relevant to you while you are online. Our Web Partners also use this information to develop and improve their websites, advertising, and the products and services they offer, as well as for research purposes.

Opt-Out

Please click here in order to opt-out of NebuAd's information collection for the delivery of 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.

Third Party Links and Websites

The advertisements we or our third party technology vendors deliver may contain links to other websites, including those of our Web Partners. NebuAd is not responsible for the privacy practices, policies or the content of such websites. NebuAd encourages our Web Partners, including those within our advertising network, to adopt privacy policies that fully inform the user about the Web Partner's information collection practices, as well as their use of a third-party advertising network, and to offer choice regarding the ad networks' services. We encourage you to read the posted privacy policies of our Web Partners and whenever interacting with any website to learn more about the privacy practices of that website. Similarly, we do not have access to, or control of, the cookies that may be set by a third party, including those of our Web Partners, and this Privacy Policy does not cover the use of cookies by any third party.

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 or our third party technology vendors collect.

Information Sharing

We share the non-personally identifiable user information that we or our third party technology vendors collect with the Web Partner that owns or operates the website from which the information was collected, or the Web Partner whose advertisement the user clicked on. We also share this information with those third parties that are authorized by the Web Partner to receive it. We share the derived segmentation constructed from the information we or our technology partners collect only with the Web Partner that owns or operates the website(s) or the advertising from which the information was collected, or with a third party that is authorized by the Web Partner to receive this information. Our Web Partner may use or share these segments in accordance with the terms and conditions of its own privacy policy and subject to such other contractual restrictions imposed by NebuAd. This information does not identify a user individually.

We may also share with third parties, including our Web Partners, certain pieces of aggregated, non-personally identifiable information about 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 a user individually.

We sometimes use third party contractors, including third party technology vendors, 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.