Archive for June, 2009

Microsoft privacy policy changes: mostly housecleaning

June 27, 2009

Last week Microsoft made a few changes to their privacy policy pertaining to advertising. Nothing too dramatic, but since we’re tracking these things, here are the relevant bits with commentary from yours truly.

Display of Advertising

Many of the Web sites and online services we offer, as well as those of our partners, are supported by advertising. Through the Microsoft Advertising Platform, we may display ads on our own sites and the sites of our advertising partners.

When we display online advertisements to you, we will place aone or more persistent cookiecookies on your computer in order to recognize your computer each time we display an ad to you. The cookies we use for advertising have an expiry date of no more than 2 years. Because we may serve advertisements on many different Web sites, we are able to compile information over time about where you, or others who are using your computer, saw and/or clicked on the advertisements we display. We use this information to make predictions about your characteristics, interests or preferences and to display targeted advertisements that we believe may be of interest to you. We may also associate this information with your subsequent visit, purchase or other activity on participating advertisers’ Web sites in order to determine the effectiveness of the advertisements.

While we may use some of the information we collect in order to personalize the ads we show you, we designed our systems to select ads based only on data that does not personally and directly identify you. For example, we may select the ads we display according to certain general interest categories or segments that we have inferred based on (a) demographic or interest data, including any you may have provided when creating an account (e.g. age, zip or postal code, gender), demographic or interest data acquired from other companies, and a general geographic location derived from your IP address, (b) the pages you view and links you click when using Microsoft’s and its advertising partners’ Web sites and services, and (c) the search terms you enter when using Microsoft’s Internet search services, such as Live Search. For more information about how we personalize ads, and the segments we use, visit Personalized Advertising Segments.

When we display personalized ads, we take a number of steps designed to protect your privacy. For example, we store page views, clicks and search terms used for ad personalization separately from your contact information or other data that directly identifies you (such as your name, e-mail address, etc.). Further, we have built in technological and process safeguards designed to prevent the unauthorized correlation of this data. We also give you the ability to opt-out of personalized ads. For more information or to use the opt-out feature, you may visit our opt-out page.. In addition, you can go to the Network Advertising Initiative, which offers a single location to opt-out of ad targeting from member companies.

We also provide third party ad delivery through our Atlas subsidiary, and you may read. For more information, visit the Atlas privacy statementwebsite at: http://www.atlassolutions.com/privacy.aspx/.

Although the majority of the online advertisements on Microsoft sites are displayed by Microsoft, we also allow third-party ad serving companies, including other ad networks, to display advertisements on our sites. These companies currently include, but are not limited to: 24/7 Real MediaAdvertising.comBidclixBlueStreakBlueStreakBurst MediaBurst MediaDoubleClickDoubleClickEuroClickEuroClickEyeblasterEyeblasterEyeWonderEyeWonderInterpollsFalkKanoodleInterpollsMediaplexKanoodlePointrollMediaplexTangoZebraPointrollYahoo! Publisher Network, TangoZebra, Yahoo! Publisher Network, andZedo Zedo.

These companies may offer you a way to opt out of ad targeting based on their cookies., and some of them are also members of the Network Advertising Initiative. You may find more information by clicking on the company names above and following the links to the Web sites of each company. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies.

Two notes:

  1. Looks like some spring cleaning on the list of third-party ad networks that Microsoft uses in its role as a site publisher. Nice to see that all of them are already in the privacychoice database. Every publisher should have such a list in their privacy policy, and it should be automatically and continuously updated (stay tuned!).
  2. As for the two-year cookie lifetime, I suppose this is helpful in the sense that if the cookie is deleted and never heard from again, there is an outer limit on the duration of any any associated profile (unless it is also associated with an IP address perhaps). But since the two-year period renews every time the cookie is seen, this should not be confused with a server-side deletion policy. It would be ideal if Microsoft could provide a deletion time frame  for the data collected with these cookies, even if it needs to acknolwedge that different policies apply to different services in their network based on unique business needs.

AdSense interest-based targeting: how many publishers are on board?

June 26, 2009

When Google rolled out interest-based targeting in March, they called on each of their Adsense publishers to revise their privacy policies:

Your posted privacy policy should include the following information about Google and the DoubleClick DART cookie:

* Google, as a third party vendor, uses cookies to serve ads on your site.
* Google’s use of the DART cookie enables it to serve ads to your users based on their visit to your sites and other sites on the Internet.
* Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

So, now that we’re three months past the announcement, just how many AdSense sites have complied with this directive and opted-in to interest based advertising?

Other than some apocryphal findings, I haven’t seen a reported number, but perhaps one rough way to measure it is to see how many privacy policy pages the search engines show as having that required link to Google’s privacy policy. Each search engine provides its own answer:

On Google – 93,600
On Yahoo! – 78,000
On Bing – 21,100

That’s a wide variation, but even if you take the high one, you’re still talking about what’s likely a small percentage of the total number of AdSense sites, although potentially a high percentage of AdSense traffic (only Google knows).

Does this reflect publisher hesitation about behavioral targeting? Uncertain impact on ad revenue? Inattention?  AdSense malaise?

———————-

NB This decidedly unscientific exercise depends on the construction of my search query, which no doubt may be interpreted differently by each search engine. Here’s the query:

“privacy policy” AND link:http://www.google.com/privacy_ads.html OR “http://www.google.com/privacy_ads.html”

The idea is to only capture pages that (1) are site privacy policies; and (2) either have the URL in searchable text or have the URL as a hypertext link.

If there are any search experts out there with suggestions on how this query could be structured better, please let me know!

Mediaplex-Valueclick (quietly) joins the NAI

June 24, 2009

Mediaplex, one of the ValueClick subsidiaries, has joined the Network Advertising Initiative, joining other recent entrants, Quantcast, BurstMedia, richrelevance.

New language yesterday on their privacy page:

Mediaplex is a member of the Network Advertising Initiative (“NAI”). The NAI is a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards. For more information, please visit www.networkadvertising.org.

With the increasing regulatory attention to behavioral targeting, ad networks can no longer afford to go-it-alone without any industry oversight. I wouldn’t be surprised if we see several new NAI members a week through the summer.

Observation: you rarely see any public announcement when new companies join the NAI. Does that just reflect concern about any association with behavioral targeting? Or is the NAI saving up for a big announcement?

Confirmed: Quantcast joins NAI + comments on the good, the bad and the interesting

June 22, 2009

As mentioned here several weeks ago, Quantcast, which collects user information across thousands of sites, has officially joined the Network Advertising Initiative.

The relevant changes to the Quantcast privacy policy follow below. Here are some quick observations:

  1. Interesting: The Quantcast opt-out only applies to their advertising delivery services. They do not allow consumers to opt out of tracking for the purposes of audience measurement.
  2. Good: The policy confirms that Quantcast uses Flash cookies, and states that those are only used for audience measurement of Flash applications and not for behavioral ad targeting. There is no Flash cookie opt-out provided, which aligns with their theory that no opt-out is necessary for audience measurement.
  3. Good: They have a direct link to their opt-out on their top page. Not prominent, but it is there at least.
  4. Good: They now have a deletion policy (called for by the privacychoice best practices for opt-outs). Log data is retained indefinitely for audience research and 13 months for advertising purposes, which puts them among the companies with shorter retention periods (at least for advertising).
  5. Good and Bad: They fixed the issues I mentioned with their prior implementation (unique cookie value), and now have a straightforward, non-unique opt-out cookie. However, they assign a cookie deletion date/time based on the date/time when first set, which — doh! — means the cookie is no longer non-unique.
  6. Not so good: The policy does not expressly state that if you opt-out, behavioral information will not be collected and shared; it only says that if you opt out you will not receive interest-based advertising and content.  A better practice would be to make it clear no information is collected from opted-out users for any purpose other than audience measurement.

Quantcast Privacy Policy

[Effective January 20June 17, 2009]

Quantcast provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of Personally Identifiable Information we receive through our website at www.quantcast.com(the “Quantcast.com Site”), as well as through our Internet audience ratings servicemarket research services, which collectscollect and analyze data across the Web through the Quantcast Tags, as described below (the (“Market Research Services).), and our content and relevant advertising delivery service (“Delivery Service”) (the Market Research Services and the Delivery Service, collectively, the “Services”). This Privacy Policyapplies Policy applies to information that you provide to us when you use our Services as a member of our Quantcast PublisherMeasurement Program (a “Quantcast Publisher”) or as user of Quantcast Marketer (“Marketer Client”), but also when you simply access or use any information or content appearing on the Quantcast.com Site, whether as a registered user (a “Registered User”) or as a non-registered user just browsing the Quantcast.com Site (a “Quantcast Visitor”). This Privacy Policy also explains what type of information is collected if you visit third party websites serving content tagged by Quantcast Publishers or Marketer Clients with Quantcast Tags. We may change the Privacy Policy from time to time. Please consult this Privacy Policyregularly Policy regularly for any updates.

Quantcast is a member of the Network Advertising Initiative (“NAI”) (http://www.networkadvertising.org) and is in compliance with the NAI’s Self-Regulatory Principles.

Personally Identifiable Information means information about you that can be used to contact or identify you. Personally Identifiable Information may include, but is not limited to, your username, your name, phone number, email address and home and business postal addresses.

Information Collection and Use

Quantcast Publishers and Marketer Clients

  • We require Quantcast Publishers and Marketer Clients to provide certain Personally Identifiable Information when first becoming Quantcast Publishers or Marketer Clients. We may also request additional Personally Identifiable Information from time to time thereafter. Providing such additional Personally Identifiable Information is entirely optional, although some Quantcast.com Site features may not work without it.
  • For Quantcast Publishers and Marketer Clients, we use your Personally Identifiable Information mainly to provide the Services to you, as applicable, and to administer your inquiries. We may also use your Personally Identifiable Information to contact you with Quantcast newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.

Registered Users

  • If you do not have a website that you want to measure, but you do want to access or use certain information, content, or tools on the Quantcast.com Site or receive our newsletter or other marketing materials and information, you may be required to register and to submit certain Personally Identifiable Information to us. This includes user name, password, email address, physical address, and telephone number, as well as any other information that you decide to provide us with. Your profile information and your name may be displayed in the Quantcast network to enable you to connect with other people on the network, as specified by you in your privacy settings.
  • If you contact us by email through the Site, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you.
  • In addition, we may use your Personally Identifiable Information to contact you with Quantcast newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.

Log Data

  • “Log Data” means information sent by your browser such as your computer’s IP address, pixel code, referring HTTP location, current HTTP location, search string, time of the access, browser’s time, any searches made on the applicable website, and other statistics.
  • When you visit the Quantcast.com Site, whether as a Quantcast Publisher, Marketer Client, Registered User or Quantcast Visitor, our servers automatically record and collect Log Data sent by your browser. We use the Log Data to monitor and analyze the use of the Quantcast.com Site and the Services, for the Quantcast.com Site’s technical administration, to increase the Quantcast.com Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, some of this information is collected so that when you visit the Quantcast.com Site again, it will recognize you and will be able to serve content, advertisements, and other information appropriate to your interests.
  • We also collect Log Data each time you visit third-party websites serving content that has been tagged by Quantcast Publishers or Marketer Clients with Quantcast Tags. We analyze such Log Data from different websites and combine it between sites and with other data and informationnon Personally Identifiable Information to produce the Reports that are made available on the Quantcast.com Site, and to enable web publishers to deliver to and advertisers to deliver audience segments that are appropriate for their products or services. This combined data is also used by us and our partners to serve you content, advertisements, and other information tailored to your interests.
  • Our clients use our Market Research Services to understand their current and historical audience characteristics and we retain Log Data for this purpose indefinitely. We retain the ability to use Log Data to provide our Delivery Service for 13 months to accommodate seasonality.
  • We do not link Log Data to any other Personally Identifiable Information about you or otherwise attempt to discover your identity. We make efforts to require our Quantcast Publishers and Marketer Clients to ensure that any such third party website post adequate privacy policies and otherwise protect the privacy rights of their visitors. Check the privacy policies of websites tagged with Quantcast Tags for information regarding the applicable privacy practices.

Cookies

Like many websites, we use cookies on the Quantcast.com Site (by placing or reading them via your browser) to save your registration ID and login password for future logins to the Quantcast.com Site. We also utilize session ID cookies to enable certain features of the Quantcast.com Site, to better understand how you interact with the Quantcast.com Site and to monitor aggregate usage by Quantcast Users and web traffic routing on the Quantcast.com Site. Third party advertisers on the Quantcast.com Site may also place or read cookies on your browser. We also use cookies when you visit websites with content tagged by Quantcast Publishers or Marketer Clients with Quantcast Tags, to collect Log Data, as described in the Log Data section above. You can instruct your browser, by changing its options, to stop accepting browser cookies or to prompt you before accepting a cookie from the websites you visit. In addition, we use Flash cookies in connection with our Market Research Services to measure certain Flash content such as animation, games and videos. Similarly to browser cookies, Flash cookies are used to remember settings, preferences and usage, but are managed through a different interface than the one provided by your web browser. If you want to delete Flash cookies, please access your Flash Player settings management tool available on Adobe’s web site. However, if you do not accept cookies, however, (whether browser or Flash cookies), you may not be able to use all portions of the Quantcast.com Site or all functionality of the Services.

Opt-Out Option
If you prefer not to receive interest based content and ads enabled by Quantcast, you can always opt-out by clicking on our “Opt-Out” link
here or by accessing the NAI’s opt out-tool here. After you opt-out, you will not receive interest based content and advertisements enabled by Quantcast. Please note that opting-out does not turn off other advertisements or other ad delivery solutions (non-Quantcast) that address advertising based on demographic, interests, or other forms of audience based data.

The foregoing opt-out does not cover the collection of Log Data for the purpose of providing our Market Research Services (though no ads are sent to you in connection with such services).

Information Sharing and Disclosure

Log Data and Aggregate Information. We may share the following information with third parties, including, but not limited to, vendors that support the operation of our Services and entities involved in the delivery of advertisements: Log Data collected on both the Quantcast.com Site and third party websites tagged with Quantcast Tags (as described in the Log Data section above), as well as aggregated anonymized information resulting from the analysis of such Log Data for a variety of purposes, including, but not limited to, conducting industry, traffic and demographic analysis, and enabling web publishers to deliver to advertisers audience segments that are appropriate for their products or services.

Comments or Submissions. User Interaction. In addition to your username, any comments or submissions (“Unsolicited Information”) that you post to the Quantcast.com Site, whether as a Quantcast Publisher, a Marketer Client or as a Registered User, will be publicly available. All such Unsolicited Information will be deemed to be non-confidential and Quantcast will be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution. You should be aware that, if you voluntarily disclose Unsolicited Information online, that Unsolicited Information can be collected and used by others. For example, if you post your email address in comments sections or online forums, you may receive unsolicited messages from others. In addition, if you decide to request a copy of the Reports or other content or information from Quantcast Publishers or Marketer Clients or otherwise interact with other users, certain information that you provided to us during the registration process, such as, for instance, your name, e-mail address, company name, and industry, as well as any other information (including Unsolicited Information) that you disclose in connection with any such communications may be collected, used and disclosed for the purpose of satisfying your request or otherwise allowing such user interaction. Quantcast has no control over the use of Personally Identifiable Information that you voluntarily post in public forums or otherwise disclose while interacting with other users, whether Quantcast Publishers, Marketer Clients or Registered Users. Any such Personally Identifiable Information you choose to disclose should reflect how much you want other users to know about you. We encourage our Quantcast Publishers, Marketer Clients and Registered Users to think carefully about what information about themselves they disclose in their comments or submissions.

Service Providers. We may employ third party companies and individuals to facilitate the Services, to provide the Services on our behalf, to perform services related to administration of the Services (including, without limitation, maintenance, hosting and database management services, and administration). These third parties have access to your Personally Identifiable Information and Log Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement. Quantcast cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We disclose Personally Identifiable Information and Log Data to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Quantcast or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being illegal or legally actionable.

Business Transfers. Quantcast may sell, transfer or otherwise share some or all of its assets, including your Personally Identifiable Information and Log Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

Burst Media and richrelevance join the NAI

June 19, 2009

Two new additions noted today on the Network Advertising Initiative site:  Burst Media (display advertising for the long tail) and richrelevance(product recommendations for retail sites). It’s particularly interesting to see richrelevance here, since you wouldn’t think of them as a “network” unless the user information gathered on individual retail sites is leveraged across other sites using their technology. A quick review of their site didn’t reveal whether information is used across sites in this way; you might not expect larger retailers to participate in a way that  benefits competitors.

These sites are now up to date in the privacychoice database, and you can see summaries of their privacy policies here. Something tells me that we’re going to see a flood of new NAI members in the next few months.

Coremetrics data syndication: unfinished business

June 19, 2009

Coremetrics primary business has been to provide site analytics for web publishers.  In typical fashion, customers install Coremetrics tags on all of the pages in their website, which generate user clickstream information that the Coremetrics system turns into insights for the site operator. According to their site, Coremetrics serves over a thousand customers.

Coremetrics recently announced a significant extension to this platform, to allow their analytics customers to “syndicate” Coremetrics’ clickstream information across multiple behavioral ad networks, including Dotomi, Audience Science, OpenX, Choicestream and [x+1]. This is interesting because even if Dotomi tags are not on the publisher’s site, the user behavioral information gathered by Coremetrics can be provided to Dotomi in order for Dotomi to deliver ads to that user on any website in the Dotomi ad network.

Coremetrics explains the benefits in their whitepaper (pdf): “Better segmentation and targeting are achieved when advertisers and ad networks can leverage detailed information about web site visitor behavior. Collecting rich activity data and passing it to multiple ad networks is a complicated, expensive, and time-consuming endeavor.”

In this screenshot you can see the options for syndication of user profiles.

coremetrics

Presumably, no personal information is ever passed to an ad network, and to be certified to participate, an ad network must agree to limitations on how syndicated user data will be used and retained. Those limitations probably include a commitment not to add the user information into the network’s general data pool, lest its value be captured by the network’s other participants. Those limitations would also further the consumer’s interest in not having behavioral information more widely distributed than intended.

Those are probably safe assumptions, but the Coremetrics privacy policy doesn’t confirm them either way, and has not been updated since January. Here’s how the policy explains the use of collected data:  “Our clients use our Services to understand more about visitors to their web sites. Clients then apply this understanding to their web sites to provide web environments that save visitors time and make the sites easier to use.” To my mind, that doesn’t capture syndication of cookie-based information for behavioral targeting. Nor does the Coremetrics opt-out disclosure really work anymore — it promises that, if you don’t opt-out, your “data will be presented as part of a pool of general, anonymous visitors.” Unless I’m reading this wrong, that’s not the case anymore. (PS I invite Coremetrics comments on this — two emails to their privacy address have yet to receive a reply.)

In addition to fixing these issues, the Coremetrics privacy statement should specify which companies may have access to syndicated profile information, and what policies they follow. You can check out our summary of those policies here.

Coremetrics no doubt will fix these issues, but there are larger lessons here. First, companies like Coremetrics who are positioned to leverage user information for targeting applications are going to do so, but they need to take care that their privacy practices stay in step.

Second, the use and syndication of user behavioral information is becoming increasingly complex as data moves between different companies in the targeting ecosystem. This calls for better consumer disclosure about these practices, particularly the inter-company agreements that govern data handling. Coremetrics has an opportunity to show the way through a robust disclosure in their privacy statement and opt-out process. In the mean time, at privacychoice we’re working on ways to make those disclosures more easily found and understood by consumers, together with the ability to opt-out for those who aren’t comfortable.

Compare the privacy policies of the top 10 ad networks

June 18, 2009

This blog has been quiet lately, since we’ve been hard at work on the next phase of the privacychoice service — a consumer-friendly presentation of the privacy policies of hundreds of companies that collect information across websites. We’re not quite ready to take off the wraps, but since online privacy is the focus of some important hearings on Capitol Hill today, I thought it might be useful to give readers a quick preview:

10 Top Ad Network Policies Compared

As you can see, we’ve lined up the stated policies of the top ad networks based on five key areas: Anonymity, Sharing, Oversight, Sensitivity and Deletion. We haven’t focused on areas where their disclosures are largely uniform and most likely less relevant to consumers — security of information, transfer upon change of control and such.

Stay tuned for more detailed research across the entire set of companies we have reviewed. As always, input is much appreciated!

Mindset Media: privacy policy revisions

June 14, 2009

Since we’re tracking these sorts of things, here are recent changes to the Mindset Media privacy policy (for their ad network). The substantive change seems to be that they will disclose “cookie-level” anonymous information to publishers in their network, in addition to aggregate information. Also a more affirmative statement of NAI membership and adherence to NAI policies.

One thing that may be less clear in the new version– what user information is provided to advertisers?

Mindset Media, LLC is an internet ad-technology company that lets online advertising network that delivers Advertisers’ ads on Publishers’ Sites to mass audiences of anonymous Sitepublishers identify their site visitors who have specificanonymously on the basis of common personality traits, or Mindsets,. This identification lets publishers deliver audiences with similar personality traits to advertisers making online ad buys from these publishers. Publishers that use our ad technology participate in common. our Publisher Network, which gathers the anonymous data used in our ad technology.

Mindset Media respects the right of all internet users to privacy, and we respect the relationship between Publisherspublishers and their Sitesite visitors. Consequently, we have developed this statement to detail the ways we collect and use data throughout our Publisher Network.

Data Collection and Usage

Personally Identifiable Information (“PII”)

Personally identifiable information is data that can be used to identify a specific internet user and may include the user’s name, address, telephone number, and email address. Mindset Media does not collect or use personally identifiable information about visitors to Sitessites in our Publisher Network.

Non-Personally Identifiable Information (“Non-PII”)

Non-personally identifiable information is data that, by itself, cannot be used to identify a specific internet user and may include browser type, operating system, address of a specific web page, and time that a specific web page was requested. Mindset Media collects and uses only non-personally identifiable information about visitors to Sitessites in our Publisher Network.

Disclosure of Information

Mindset Media may disclose information as follows:

  1. 1. To Advertiserspublishers in theour Publisher Network, as aggregated audience anonymous cookie-level profiling information for planning ad and assessment of campaign performance,content delivery and audit validation; and as audit aggregated information on specific ad presentations for validation of ad and audience delivery.
  2. To Publishers in the Network, as aggregated audience profiling information for site performance and inventory delivery, and as audit information for validation of ad and audience deliverycomposition reporting.
  3. To Mindset Media employees and service providers, as required to provide business and technical support to us. All employees and service providers are signators to our non-disclosure agreement or are similarly bound by professional requirements.
  4. To law enforcement or other governmental agencies, as required by law

Temporary Use

In order to deliver targeted advertisementsenable our ad targeting technology, Mindset Media must retainretains Non-PII on visitors to Sitessites in our Publisher Network. Mindset Media will not retain information on any Sitesite visits for more than two years.

Web Beacons

Publishers in our Publisher Network may use web beacons (also commonly referred to as pixels, ad tags, and page scripts) to help us gather Non-PII on visitors to Sitessites in our Publisher Network. Web beacons are clear 1×1 pixels that appear invisible to web users. Mindset Media will never use web beacons to collect personally identifiable information from Visitorsvisitors to Sitessites in our Publisher Network.

Use of Cookies

Mindset Media uses cookies to enable our ad targetingtechnology. Cookies are small text files that are stored on the computers that visit Sitessites in our Publisher Network. The cookies allow us to associate timecodesnon-PII data, such as browser type, operating system, address of a specific web page, and URLs of pageviews in the Networktime that a specific web page was requested, with anonymous IDs of Sitesite visitors. We cannotWecannot and do not use our cookies to obtain any personally identifiable information.

For more information about Mindset Media cookies, please refer to our Use of Cookies Statement located in the Privacy section of our website.

Visitors to sites in theour Publisher Network may also choose to opt out of the Mindset Media Publisher Network through our industry-standard cookie opt-out program. Alternatively, Visitorsvisitors may also choose to opt out of the Mindset Media Publisher Network through the Network Advertising Initiative’s Consumer Opt-out Program.

Information Security

Although there is always a risk of unauthorized or uncontrollable access to any computer system, Mindset Media takes security very seriously. Mindset Media maintains security measures to protect our data from unauthorized access, loss, alteration, or misuse. These measures include physical, technical, and managerial procedures necessary to ensure information security.

Privacy Compliance

Mindset Media is a member of the Interactive Advertising Bureau (IAB) and complies with the IAB’s privacy standards and guidelines for advertising units.

For more information on the Interactive Advertising Bureau, please visit them at: www.iab.net.

Mindset Media is a Full Compliance Member of the Network Advertising Initiative (NAI) and participates in the NAI’s industry-standard), a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards. Mindset Media complies with the NAI’s Self-Regulatory Principles and participates in the NAI’s consumer opt-out program.

For more information on the Network Advertising Initiative and its consumer opt-out program, please visit www.networkadvertising.org.

Additional Notices and Disclosures

Third Party Organizations

From time to time, Mindset Media partners with select organizations to help us improve the quality of our online services. We will not request, or knowingly accept or retain, any PII from these organizations.

If you have questions or concerns about any third party we work with, please contact us.

Changes to Privacy

Mindset Media may change this policy without notice and may do so at any time by posting an updated privacy policy on our website. Please review the Privacy section of our corporate site periodically to note any changes.

Sale of Assets

In the event that Mindset Media is acquired by another company, we may transfer any or all information to the acquiring organization.

Questions and Comments

We encourage you to contact us about this privacy policy. For more information, or if you have questions or concerns about this privacy policy, please contact us at privacy@mindset-media.com or

Mindset Media, LLC
828 S. Broadway
Suite 100
Tarrytown, NY 10591