Lotame’s Revised Privacy Policy: One step up, two steps back

April 22, 2009

Lotame, a behavioral targeter focused on social networks, updated their privacy policy yesterday (see full comparison below).  On balance, the new policy looks less privacy-friendly in important respects.

Here are the details:

1.  They added a reference to the Network Advertising Initiative, although as of the time of this post, they are not listed on the NAI opt-out page.  Perhaps that’s coming soon?

2.  They deleted a promise not to target based on sensitive information, including health-related information.  Pharmaceutical marketing appears to be on Lotame’s radar, having recently sponsored a conference on the topic. If this signals a plan to get more aggressive in behavioral targeting in sensitive areas like health, Lotame is swimming against the tide and tempting the regulators.

3.  On data retention, a promise only to retain user info for as long as the business need continues has been replaced by a promise to keep it only nine months after collection.  (Same question here as we had for BlueKai   — do the profiles constructed with user information live on past the nine month period, even if the cookie-based logs are trashed?)

4.  Finally, maybe this is a detail, but they deleted a statement that said, if they make material changes to their policy, those will only apply to data collected after announcement of the changes.  So, if Lotame’s practices truly have changed as to sensitive information, does this mean that they can now use my sensitive information for targeting even though  they collected it under a prior promise not to use it?

Overall, Lotame gets credit for their earlier adoption of an opt-out process with a non-unique cookie, and (once they complete it) adding their opt-out process to the NAI system.  But these new steps backward are concerning (particularly in the area of sensitive information).  If Lotame is indeed to be added to the NAI group, Charles Curran of the NAI should look closely at these changes.


Last Updated:   March 6April 21, 2009

Lotame and Consumers:  Our services are designed to provide consumers with relevant advertising and content at Web sites you visit. These marketing activities help to underwrite the cost of the content and services made available to you online. 

As part of Lotame’s commitment to respect privacy concerns and implement industry-recognized standards, we are a member of the Network Advertising Initiative (NAI). Lotame complies with NAI’s Self-Regulatory Principles which are designed to inform consumers about data collection and advertising practices across multiple web sites and provide the ability to opt out. For more information or to opt-out of behavioral advertising by Lotame or other NAI member companies, please visit the NAI web site at www.networkadvertising.org.

 Data We Collect and Use:  To deliver our services, we collect, organize, and use data reflecting your interactions with a variety of Web sites.  The information we use includes items such as the date and time you visited a Web site, your browser information, your IP address, your browsing behavior, and interests you express or imply at social networking sites or other Web sites you visit. We recognize your computer over time by setting a unique browser cookie which your browser relays to our servers when you visit Web sites that are our customers.  We analyze this non-personal information and organize it into anonymous user profiles, groups, and audiences, based on factors such as age, gender, geography, interests and online actions.  We and our customers then use these anonymous user profiles, groups, and audiences to design and deliver targeted advertising campaigns or other relevant content.  We and our customers also use this data for other related purposes (for example, to do research regarding the results of our online advertising campaigns or to better understand the interests or activities of Web site visitors.)

The behavioral categories we use to tailor the ads you may see or for related purposes do not use personal information such as your name, address, e-mail address, phone number, birth date or social security number.  Our technology and services are designed to limit our use of consumer data to anonymous, non-personal information.  In addition, we do not tailor ads based on behavioral categories that are deemed sensitive by the Network Advertising Initiative (NAI).  
Opting Out:  We provide you with the ability to opt-out of our use of information about your previous browsing  to tailor the ads you see.  You can opt-out by clicking here here and following the instructions provided.  Note that after choosing to opt-out, if you use a different computer or a different browser, or if you delete or block browser cookies, you may need to repeat the opt-out steps.  Most web browsers also enable you to block browser cookies. You can refer to your web browser’s documentation to get more information on how to block or delete cookies directly through your browser settings.  
Data Sharing:  When you visit a Web site that shares information about your activity with Lotame, we will use that information to tailor relevant ads to you at that and other Web sites you visit, or for research and analysis.  We may also share non-personal information with companies such as advertisers, agencies, ad networks, or exchanges to enable them to analyze user behaviors or to tailor the ads that you encounter.
There are other limited circumstances in which we may share data.  We may provide access to the non-personal information we collect to service providers who are assisting us with storage, analysis, or other services.  These service providers are subject to confidentiality restrictions, and are not authorized to utilize the information in any way other than to provide their services to us.  If our company is sold, assigned, transferred, merged, files for bankruptcy protection, or undergoes some other change to its corporate form, information may be transferred as part of that transaction or change.  In these instances, we will take steps to ensure that our data is maintained in accordance with this privacy policy.  In special cases, we may also be required to release information in order to comply with requests from law enforcement, government agencies, and similar entities, or to otherwise protect our clients and users.  
Data Retention:  We retain the anonymous user data we collect only for so long as it assists us in fulfillingup to nine (9) months from the business needs described above.date of its collection.    
Security:  Lotame has implemented security measures which are reasonably designed to protect the user data which Lotame collects from unauthorized access, disclosure, or modification.
The Lotame.com Web Site:  Lotame collects non-personally identifiable usage data at http://www.lotame.com, which we use to improve our web site and services.  In response to requests for information, Lotame also collects voluntarily-supplied personal contact information.  We do not share, sell, rent or trade any contact or personally identifiable information with third parties (except with service providers in the manner described above).  If you would like to update, delete, or revise any personal information you submitted to us through lotame.com, please send your request to admin@lotame.com. admin@lotame.com.  

Changes:  We reserve the right to revise this privacy policy at any time.  If we change the policy, we’ll notify you by posting the new policy here, changing the date at the top, and indicating on our homepage that the privacy policy has been updated.  If we make any material changes to the policy, the material changes will only apply to data we collect after we post and announce the revised policy.  

Contact Us:  To contact us with any questions, comments, or suggestions, please email us at admin@lotame.com or write to us at the address below.  

Lotame Solutions, Inc.
6085 Marshalee Drive
Elkridge, MD 21075


One Response to “Lotame’s Revised Privacy Policy: One step up, two steps back”

  1. […] Lotame’s Revised Privacy Policy: One step up, two steps back […]

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