AD PLATFORM PRIVACY POLICY


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Last Updated May 14, 2014

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Say Media, Inc. ("Say Media," "we" or "us") knows that you care how information about you is used and shared. This Privacy Policy explains how Say Media collects and uses information at its website located at www.saymedia.com and at other websites and mobile services provided by Say Media (collectively the "Network Websites"). This Privacy Policy also explains how Say Media collects and uses information received in connection with advertisements placed by Say Media on the Network Websites and on third party affiliate websites, as part of the Say Media Ad Platform Online Program (the "Program") (the Network Websites, Say Media advertisement placements, and Program are collectively referred to as the "Say Media Services"). This Privacy Policy also explains how you can control the collection, correction and/or deletion of certain types of information that we collect. We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. Further, this Privacy Policy does not apply to any websites, webpages, blogs, applications, widgets or other services operated by any third party, including our affiliates, advertisers, providers and partners.

Say Media is a member of TRUSTe's TRUSTed Data Program, signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us through one of the methods listed below. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program only covers information collected by Say Media through their network of third-party Web sites and does not cover information collected through mobile devices.

1. Information We Collect

A. Personally Identifiable Information. In general, Say Media does not collect personally identifiable information on the Say Media Services, except as set forth below. For purposes of this Privacy Policy, "personally identifiable information" is data intended to be used to identify, contact or locate a person, including, name, address, telephone number or e-mail address and any other information (even if non-personally identifiable) provided in combination with such personally identifiable information.

The advertisements we deliver may offer the ability to interact, including playing a game or viewing a video. The ad may also give you the opportunity to provide the advertiser with information about yourself. In some instances, if you choose to interact with an advertisement or provide an advertiser with information about yourself, Say Media may collect information on behalf of the advertiser. In that case, the advertiser's privacy policy would apply to the data collected and we will abide by the instructions given to us by the advertiser in our handling of the data. Say Media will not associate any information (non-personally identifiable or personally identifiable) we collect for an advertiser with any other information we may have collected about you through the Say Media Services.

B. Non-Personally Identifiable Information. When you visit the websites of third parties such as advertisers, third-party advertising networks, third-party advertising serving companies, and Say Media business partners, vendors and service providers may collect non-personally identifiable information. For purposes of this Privacy Policy, "non-personally identifiable information" is data that is not personally identifiable. Say Media and these third parties may implement certain technologies to enable the collection of such information. An explanation of these technologies is below.

Cookies Information: The Say Media Services may send one or more cookies—a small text file containing a string of alphanumeric characters—to your computer that uniquely identifies your browser. A cookie may also convey information about how you browse the Say Media Services. Say Media uses session, persistent, Flash and browser cookies. The use of cookies by Say Media does not allow us to gather personally identifiable information about you. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to a website. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. You can set your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Say Media Services may not function properly if the ability to accept cookies is disabled. To manage Flash cookies please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Device Identifiers: When you access the Say Media Services by or through a mobile device, we may access, collect, monitor and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device that uniquely identify your mobile device and are used by Say Media to enhance your use of the Say Media Services. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by Say Media. A device identifier may convey information to us about how you browse the Say Media Services. A device identifier does not collect or share any personally identifiable information about you. However, a device identifier may be used in conjunction with other information in a manner that may constitute personally identifiable information. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Say Media Services. Some features of the Say Media Services may not function properly if use or availability of device identifiers are impaired or disabled.

Location Data: When you access the Say Media Services by or through a mobile device, we may access, collect, monitor and/or remotely store "location data," which may include GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey information to us about how you browse the Say Media Services. Location data does not collect or share any personally identifiable information about you. However, location data may be used in conjunction with other information in a manner that may constitute personally identifiable information. Some features of the Say Media Services, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

Web Beacons/Click-Stream Data: A web beacon is an electronic file that signals when a webpage, advertisement, video, other content, an email, or a newsletter has been viewed. Say Media uses web beacons in conjunction with cookies to collect click-stream data that helps us better understand how visitors move from page to page within websites. As with cookies, our web beacons do not gather personally identifiable information about you.

Passive Browser Information: Say Media collects passive browser information though its web servers. We use the passive browser information to help us understand how many visitors come to websites and where they come from, and ultimately to help us make decisions about how to deliver advertising.

Demonstrations: Say Media periodically offers visitors to its websites the ability to see demonstrations of services offered by Say Media. If you elect to view demonstrations, we may collect non-personally identifiable information in connection with the demonstration of the relevant service. Our collection, storage and use of non-personally identifiable information in connection with such demonstrations are subject to this Privacy Policy.

Log File Information: Log file information is automatically reported by your browser each time you access a web page. When you use the Say Media Services, our servers automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, data about how you interact with links on the Say Media Services, and other such information. We may display your IP address to the owners or maintainers of certain blogs, groups or communities if you post to those blogs, groups or communities and the owner or maintainer has enabled functionality for this purpose.

Scripts: A script is a short segment of computer code included in a web page or other content that can be used to set and access a cookie on your computer's hard drive and to record your activity on a website. Say Media may use scripts on third-party websites.

Third-Party Data Providers: Say Media may supplement the information it collects with other non-personally identifiable information provided by third-party data providers. The information provided may include estimates of your age, gender and your interests, but does not include personally identifiable information.

Other Third-Party Service Providers: In connection with our services, Say Media may engage third parties to provide services or to support aspects of our business on our behalf. In connection with those relationships, such third parties may collect data on our behalf. In that case, the third party would only collect and use such information as instructed by us and in accordance with this Privacy Policy.

Third Party Use of Technologies: Third parties may set and access their own cookies, use their own web beacons, and use their own scripts on and through the Say Media Services or third-party websites. How other companies use their own cookies, web beacons and scripts and the information they gather is subject to those companies' privacy policies, not this Privacy Policy.

C. Third Party Advertisements. If an advertiser asks Say Media to show an advertisement to a certain audience and you respond to that advertisement, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. In addition, third-party advertisers may use non-personally identifiable information about your visits to the Say Media Services in order to provide advertisements about goods and services that they believe may be of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here and here. This Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers for more information.

2. How We Use Your Information

A. Personally Identifiable Information. We use the personally identifiable information that we collect to operate, maintain, and provide to you the features and functionality of the Say Media Services.

If you choose to provide an advertiser with information about yourself, Say Media may collect information on behalf of the advertiser. In that case, the advertiser's privacy policy would apply to the data collected and we will abide by the instructions given to us by the advertiser in our handling of the data. Say Media will not associate any information (non-personally identifiable or personally identifiable) we collect for an advertiser with any other information we may have collected about you through the Say Media Services.

B. Non-Personally Identifiable Information. We use non-personally identifiable information, including cookies, device identifiers, location data, web beacons/click-stream data, passive browser information, demonstration data, log file information, and scripts to: (a) provide custom, personalized content and information; (b) monitor the effectiveness of our services; (c) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (d) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; (e) monitor and prevent fraud and abuse; (f) keep track of preferences you specify while you are using Say Media Services; (g) conduct research to improve Say Media Services; (h) monitor advertising-related metrics, in order to provide you with more helpful and relevant advertising; (i) administer our business (e.g., to calculate payments due to our network websites); and (j) track user content and users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act.

Third-party advertising networks and advertisers may also use non-personally identifiable information to assist them in delivering advertising that may be relevant to your interests.

How We Share Your Information

A. Personally Identifiable Information. Say Media will not rent or sell your personally identifiable information to others. Say Media only shares personally identifiable information with other companies or individuals outside of the Say Media Services as follows: (1) with our advertisers if we have been engaged to collect data on their behalf, as described in the "Information We Collect" section above; (2) to respond to subpoenas, court orders or legal process, to assist government enforcement agencies, to establish or exercise our legal rights, or to defend against legal claims; (3) if we believe it is necessary in order to investigate, prevent, or take action regarding third-party claims or allegations, illegal activities, suspected fraud, situations involving potential threats to the safety or property of another person, violation of our Terms and Conditions of Service; or (4) as otherwise required by law. Say Media may also store personally identifiable information and user content in locations outside the direct control of Say Media (for instance, on servers or databases co-located with hosting providers).

We cannot control third parties' use of your information. If you do not want your information to be collected by or shared in this way, you can choose not to participate in these events.

B. Non-Personally Identifiable Information. In the event that we use a third party to provide services or to support aspects of our business on our behalf, Say Media may share non-personally identifiable information with the third party to be used by them only for the purpose of providing their services to Say Media.

We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Say Media Services, and as part of the function of our business. For example, we may share the number of ad views, ad clicks and content views to help calculate the payments due under the Program.

C. Transfer of Data. In the event that Say Media sells, transfers or otherwise relinquishes all or part of our assets, business offerings, or services, including any of the Say Media Services, information that you have shared with Say Media or that Say Media has collected, including both personally identifiable information and non-personally identifiable information, may be one of the business assets that will be transferred. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution. The transferred information will remain subject to the terms of this Privacy Policy or those of subsequent policies to which you have consented. If Say Media is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

3. Data Retention

Say Media retains the specific anonymous data collected and tied to your computer's unique ID as described in this Privacy Policy for a period of up to twelve months. Such data may be aggregated and used for analytical purposes indefinitely.

4. How We Protect Your Information

The security of information is important to us. We follow generally accepted standards to protect the information we collect, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

5. Compromise of Personal Information

In the event that personal information is compromised as a result of a breach of security, Say Media will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by law.

6. Your Choices About Your Information

You may, of course, decline to submit personally identifiable information through the Service, in which case Say Media may not be able to provide certain services to you. You may update or correct your account information and email preferences at any time by adjusting your account settings or contacting us at privacy@saymedia.com. You can review and correct the information about you that Say Media keeps on file by contacting us directly at privacy@saymedia.com.

If you do not want Say Media to gather non-personally identifiable information when you encounter advertisements we deliver through the Say Media Services, please click the opt-out button at the top of this Privacy Policy. The opt-out works by placing a cookie on your computer that notifies Say Media that no other cookies should be placed on the applicable computer. If this cookie is deleted, then you will need to complete this opt-out process again. If you use more than one computer, you will need to complete this opt-out process on each computer that you use. The opt-out does not mean that you will no longer see online advertisements. It means only that advertisements delivered by Say Media will not be targeted to you, based on information derived by Say Media or its third-party vendors.

You can also opt-out of receiving cookies from third-party data providers by following the instructions at: http://www.networkadvertising.org/managing/opt_out.asp. TRUSTe also provides you with ways to opt-out of behavioral tracking at: http://preferences-mgr.truste.com/. You can opt-out of receiving cookies from Targusinfo, a specific third-party data provider, by following the instructions at: http://www.adadvisor.net/optout.html. Also, because your choices are not associated with you as a particular individual, if you change computers, web browsers or cookie settings, you will need to re-implement your preferences as described above. Note that if you limit or disable cookies, this does not mean that you will not see ads on the Say Media Services. Instead, ads will be displayed that are based on passive browser information or other information that that may be provided by the Say Media Services at the time of your visit.

7. Children's Privacy

Say Media does not knowingly collect the information of, track or target children under the age of 13. In the event that we learn that we have collected information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible.

8. Governing Law

This Privacy Policy is governed by the laws of the State of California and the United States of America.

9. Changes to this Privacy Policy

Say Media may modify or update this Privacy Policy at its sole discretion from time to time, and so you should review this Privacy Policy periodically. When we change the policy in a material way, we will notify you by means of a notice on our website prior to the change becoming effective. Changes to this Privacy Policy are effective when they are posted on this page. Your continued access to the Say Media Services after the Privacy Policy has been modified and posted will signify your acceptance of such modifications.