Identified Hits

IDH Privacy Policy

This Privacy Policy is effective as of April 15, 2008

Identified Hits, Inc. (“IDH”) provides advertisers and publishers (or their agents) (our “Ad Partners”) access to a set of technologies and processes designed to display advertisements to consumers viewing a publisher’s website(s) (the “IDH Ads”).

Below, please find a description of how IDH collects, uses and discloses information we learn about users that view and/or interact with an IDH Ad, visitors to our website, registered IDH account holders and our Ad Partners.

Our primary goals in collecting information are to provide and improve the IDH website, located at www.IdentifiedHits.com (the “Site”), the IDH advertising network and related IDH technology and services (collectively, the “Services”), to administer any accounts you may have with us and to enable you to enjoy and easily navigate and use the Site and Services.

This Privacy Policy may be updated from time to time for any reason. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on the Site. Your use of our Site and Services constitutes your acceptance of the terms of this Privacy Policy as amended or revised by us, and you are advised to consult this Privacy Policy regularly for any changes.

1. Information linked to your User ID

When you subscribe to a social network service (such as Facebook, MySpace, Bebo, etc.), you will be assigned a user identifier (a “User ID”). Your User ID is used by the social network to which you have subscribed and by the applications you have installed to track both personally identifiable and non-personally identifiable information, some of which is required for the operation of these services and applications. The information that you disclose to them is governed by the privacy policies that each has in effect and their terms of service.

Your User ID is our fundamental way of identifying you.

We obtain access to your User ID through the applications you have installed or subscribed to. We use your User ID: (i) to deliver IDH Ads (and target future IDH Ad campaigns) specifically to you in accordance with your preferences or restrictions; (ii) to increase (and measure) the performance and effectiveness of an IDH Ad campaign; and (iii) to track suspicious activity and prevent fraud (including but not limited to advertising fraud). We may be provided with information that is associated with your User ID by third parties for the purpose of delivering advertising.

The following describes the sources from which we obtain information, the types of information that we collect or receive, how we use and store such information, and with whom we share such information that may be associated with your User ID.

(a) Information from social networks.

The social network to which you belong collects and maintains a large amount of information about you, including all data that makes up your profile, your relationships (friendships) with other users, and your participation in the wider social network community (such as events, groups, photos, etc.). That information resides with the social network but may be stored elsewhere by authorized third parties (such as the applications you have installed) for up to twenty-four (24) hours in accordance with the rules laid out by the social network. Your social network is responsible for allowing you to manage and remove information that you want excluded. The social network may share your data with third party applications in accordance with their terms of service. Often this requires that you explicitly grant use and access permission to these applications.

We may have access, through our relationship with the publisher of the application that you have subscribed to, to information from the social network that issued your User ID. The information we obtain is used to assist us with targeting the IDH Ads or personalizing an IDH Ad to you or to your friends. Examples of this include, but are not limited to, your age, location, name, picture, gender, and social graph. This information may be cached by us for up to twenty-four (24) hours, on either your computer (through the use of cookies) or on the IDH Ad server, for the purpose of improving the performance of the IDH Ad delivery network. If this data is aggregated or otherwise disassociated from all personally identifiable information, including User ID, then it may be stored perpetually and shared. Because information linked to your personally identifiable information is never stored for more than twenty-four (24) hours, any changes that you make to your information sharing preferences from within the social network will take complete effect within twenty-four (24) hours.

(b) Information from advertisers.

Advertisers may associate personally and/or non-personally identifiable information with your User ID. Often this will be the case when the advertiser owns or maintains the application which you have installed and interact with. Examples of this data include your preferences, tastes and interactions related to the application. We require that our advertisers procure and use their data in accordance to the policies of all relevant stake holders and maintain their own privacy policy in which they document what information they collect, why they collect it, with whom they share it, and how you may control it. However, we do not review their policies and cannot be held responsible for the actions of advertisers. If it does not violate any policies, advertisers may share the information they collect with us for the purpose of personalizing the IDH Ads they wish to deliver. This information is associated with a User ID by necessity for the purpose of ensuring that the personalized IDH Ad is viewed by the correct recipient. We do not store the information provided to us by advertisers that may contain personal information or non-identifying information for longer than is necessary to deliver the IDH Ad. We do not share the information that belongs to the advertiser with other parties. We also do not aggregate the contents of that data.

Viewers may prevent their information from being shared with us by an advertiser by opting out of receiving all future IDH Ads from such advertiser. This can be done by the viewer when an IDH Ad is received, simply by clicking the feedback link. The feedback link will disclose the website address of the advertiser who is responsible for incorporating any personally or non-personally identifiable information related to the viewer of the IDH Ad. The viewer can choose to prevent that advertiser from supplying us with ads containing personally or non-personally identifiable information of that user. Going forward, once such option has been selected, IDH will immediately discard any personally or non-personally identifying information it receives from such advertiser. Users who want to pro-actively opt out of these practices before receiving any IDH Ads must contact and notify the advertiser directly.

(c) Disclosing information to friends.

There may be cases where an advertiser will want to share your information, such as your picture, name, an interaction that you had with an ad, and/or an action that you have taken outside of the context of the ad (e.g., your use of or activity within an application), with your friends, for the purpose of using it as an endorsement of a product or service. In such cases the advertiser must request explicit permission to share such information so, making clear what information will be shared and with whom. In most cases it will be shared with all or a subset of the user’s friends. IDH has no control over the policies of the advertisers for ensuring that contacting your friends complies with all laws relating to privacy and/or that all necessary consents as may be required by applicable law have been obtained.

We will store and use the information we are provided in accordance with the instructions we receive at the time it is provided to us by the relevant owner of that information (e.g., your social network or the application you have installed). For example, if we are given, or permitted to collect, certain information from your social network, but only permitted to store such information for twenty-four (24) hours, we will abide by these instructions for such information.

Once you have granted an advertiser permission to use your information in a particular ad campaign, it is not possible for the IDH Ads containing your information to be cancelled or for the permission to share your information to be revoked for the duration of that particular ad campaign. However, if you change or update your picture or other information with the social network, the IDH Ads will display such updated information within twenty-four (24) hours (since we are not permitted, according to the social network’s terms of service, to cache information that belongs to them for any longer, even if you give us permission to use it). Once a particular ad campaign for which you have given permission to share your information expires, your information will be removed from the IDH servers.

(d) Information from your interaction with an IDH Ad.

If you interact with an IDH Ad, including but not limited to clicking any portion of it, that interaction may be logged by us or the advertiser and perpetually associated with your User ID. Such information will be considered the property of the advertiser and will not be shared by us with other third parties. The privacy policy of the advertiser will govern how they use the data. Every IDH Ad contains a feedback link that reveals that advertiser’s website which is the suggested means for finding out more about how they use their data. If you do not wish such data to be recorded you can simply avoid clicking the IDH Ad.

Clicking the feedback link or submitting feedback may result in your User ID (and the particular IDH Ad campaign information you are viewing) being logged by us. This is strictly to help us respond better to your request for more information about the IDH Ad you just saw.

(e) Server information.

We associate your User ID with certain log data our servers collect, including but not limited to your IP address, the website you are logged onto, the geographic location of the IP address you are using to access the Internet, the IDH Ads you see, and other server information that is relevant to help us prevent fraud and resolve payment disputes with publishers and advertisers. This collected log information does not contain any of the personalization text that may be present in a personalized IDH Ad. These logs may be stored perpetually solely for that purpose. They are not shared with anyone. It is not possible to opt out of being included in these logs.

 

We may also collect log data each time you visit third-party websites serving IDH Ads. We analyze such log data and combine it between sites and with other data and information to enable advertisers to deliver, and publishers to display, advertisements and other information tailored to your interests.

(f) Cookies and web beacons.

Like many websites, we also use “cookies” to collect information.  A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. The cookie we place on your computer may contain your User ID.

We use cookies to monitor the effectiveness of an IDH Ad (for example, by tracking whether you have seen a particular IDH Ad, to control the number of times you view an IDH Ad, the way in which you respond to, select and interact with an IDH Ad or any content provided therein, or the location and context in which you view an IDH Ad). We may store such a record on our server temporarily until the IDH Ad campaign completes running.

We also use cookies to make sure that any other cookies that are storing information about the user temporarily for performance reasons actually refer to the current user and not another user of the same computer. These cookies will expire quickly, often within twenty-four (24) hours when the other information about the user expires. We may further use cookies to identify the user when the user is browsing other websites that are not part of the social network to which the User ID in the cookie belongs, to collect log data related to the user, as described in the “Server information” section above.   

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. 

IDH also uses web beacons, in combination with cookies, to analyze usage patterns of users. A web beacon is typically a transparent graphic image (usually 1 pixel x 1 pixel) or a piece of Javascript code that is placed on a webpage. The use of a web beacon allows IDH to record that the user has visited that particular webpage or interacted with an IDH Ad, along with particular non-personally identifiable information that the Ad Partner may choose to include with the beacon, such as the dollar amount of a shopping transaction completed by the user.

2. Information NOT linked to your User ID

(a) Miscellaneous information.

Non-personally identifiable information may be collected from any source, including our server logs, stored perpetually, and shared with third parties, so long as it cannot be traced back to the original User ID or other personally identifiable information. Examples of this type of information include, but are not limited to, age, location, gender, applications you have installed, your preferences regarding ads (including but not limited to IDH Ads), the links you have clicked and your physical location (country, city, etc). Because such information is not associated with any user it is not possible to edit or delete this information once it has been collected. It may be used for internal planning or public announcements.

(b) Aggregate Information.

We may combine and aggregate personal and non-personally identifiable information, and in some cases aggregate it with log data or other information collected from other sources, to attempt to provide you with a better experience, to improve the quality and value of the IDH Ads, to analyze and understand how our IDH Ads are used, identify potential audiences for future targeting, tailor our Services for such audiences, and to perform industry or demographic analysis. This aggregated information may be shared with IDH’s affiliates, advertisers, employees, customers and Ad Partners.

3. Service Providers

We may employ third party companies and individuals to facilitate our Services, to provide the IDH Ads and service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and IDH Ad delivery service are used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

4.   Visitors to the IDH Website

The Site, which may be hosted in part or its entirety by a third party, is intended primarily to offer information about IDH and the Services it provides. The Site is designed so that a web visitor may generally browse it without the collection of any personally identifiable information (except for the web visitor’s IP address). When a web visitor uses the Site, IDH may collect information indirectly and automatically (through the use of cookies and web beacons, as described above) about the web visitor’s Site activity. IDH uses this activity information for internal purposes such as to administer the Site, improve and customize the Site, help IDH understand and analyze how the Site is being used and to track aggregate Site usage.

5.   Subscribers & Ad Partners

This section of the Privacy Policy applies only to information our “Subscribers” (registered IDH Account holders who have accepted the IDH Terms of Use) and our Ad Partners (IDH advertisers and publishers who have accepted the IDH Terms of Use or entered into separate agreements with IDH) may provide to IDH: (i) during registration with IDH as a Subscriber or a Ad Partner and creation of an IDH account (an “Account”), and (ii) in conjunction with their access to, participation in and use of the Site and Services. To become a Subscriber or Ad Partner, you must be at least eighteen (18) years old and otherwise capable of forming legally binding contracts under applicable law.

IDH is committed to maintaining the privacy of its Subscribers and Ad Partners.

(a) Collection of Subscriber & Ad Partner Information

§  If you choose to register and open an Account, IDH will collect personally identifiable information from a Subscriber or Ad Partner during the Account registration process (“Personal Information”). Personal Information includes, but is not limited to, name, company name, address, email address, telephone and fax numbers, Account password, bank information, credit-card type, number and expiration date, domain address for serving IDH Ads, PayPal email address, social security number and/or Federal Tax ID number and other personal information listed in the Account registration form.

§  We also collect non-personally identifiable information related to your Account (“Non-Identifying Information”). Non-Identifying Information includes, but is not limited to, details about your IDH Ad campaigns (e.g., the applications or websites that are to be promoted or used during your IDH Ad campaign), your preferences regarding IDH Ad campaign metrics and other information you provide.

§  Cookies. IDH automatically collects a Subscriber’s and Ad Partner’s IP addresses and website usage information when a Subscriber or Ad Partner logs into their Account or while using IDH Services. IDH may collect information indirectly and automatically (through the use of cookies, as described above) about the Subscriber’s or Ad Partner’s Site activity. IDH uses this activity information to help IDH evaluate how its Subscribers and Ad Partners use and navigate the Site on an aggregate basis, including the number and frequency of Subscriber and Ad Partner visits, and the length of their visits. IDH also uses the non-permanent session cookie to track and maintain a Subscriber’s or Ad Partner’s login status during their session on the site. IDH also uses this information for internal purposes, such as to help IDH diagnose any server problems, administer the Site, improve and customize the Site, or help IDH understand and analyze how the Site is being used. IDH may link IP addresses to certain personally identifiable information only when reasonably necessary to satisfy any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Subscriber and Ad Partner agreements, including investigation of potential violations thereof, or detect, prevent or protect IDH against or otherwise address criminal activity, fraud, security or technical issues.

§  Surveys. From time to time IDH may ask Subscribers and Ad Partners to participate in surveys. These surveys are entirely voluntary and a Subscriber or Ad Partner may decline to participate. If you choose to provide some of your Profile information in response to a survey, such information will be used for purposes of monitoring or improving the Site or the use and satisfaction of the Services.

(b) Information Use & Disclosure. IDH’s primary goal in collecting a Subscriber or Ad Partner’s Personal Information and Non-Identifying Information (collectively, a “Profile”) is to communicate with Subscribers or Ad Partners, provide them with a smooth and efficient experience of IDH Services and to charge advertisers and pay publishers. To this end, IDH may share Profiles with third-party service providers and IDH-related entities worldwide (e.g., its parents, affiliates and subsidiaries and their successors and assigns) in connection with communications, payments and other aspects of operating and promoting the Site and Services. We require that these entities agree to use such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures. Except as explicitly stated herein, IDH does not sell, rent or trade any Profiles to third parties.

IDH may use the information contained in a Profile in the following ways:

§  Accounts. IDH may use a Subscriber’s or Ad Partner’s name, address, email address and telephone number: (i) to enable IDH to process, validate and verify an Account; (ii) to contact the Subscriber or Ad Partner regarding Account activities or communications relevant to the Services; and (iii) to contact the Subscriber or Ad Partner about new or existing products and services or special offers.

§  Billing, Payments & Verification. IDH may use a Ad Partner’s: (i) name, address, account password, bank information or credit-card number in order (a) to process and remit fees to publishers, (b) to process and charge fees to advertiser, and (c) verify Personal Information of the Ad Partner; (ii) social security number and/or Federal Tax ID number to prepare Form 1099s if necessary and to help IDH verify such Ad Partner’s identity.

§  Service Processing. IDH uses third-party processing companies (including credit card processing companies) for billing and payment purposes. These third parties may store or retain an Ad Partner’s Personal Information. IDH may charge or bill an Ad Partner’s credit card an initial Account activation fee as described during the Account registration process. In certain cases, IDH will also use credit card information to help verify an Ad Partner’s identity. These third parties do not have any right to use the Profile information IDH provides to them beyond what is necessary to assist IDH.

§  Combined Information. We may combine Personal Information with Non-Identifying Information and aggregate it with information collected from other sources to attempt to provide you with a better experience, to improve the quality and value of the IDH Ads, to analyze and understand how our IDH Ads are used, to perform industry or demographic analysis and report on our effectiveness to prospective Subscribers and Ad Partners. We may also use the combined information without aggregating it to serve you specifically; for instance, to offer you new products or services according to your preferences or restrictions.

§  Dispute Resolution. IDH may use and disclose Profiles and other information IDH obtains from a Subscriber’s or Ad Partner’s current and past activities on the Site in special circumstances, if IDH is required to do so, if IDH reasonably believes that such disclosures will potentially mitigate its liability, or for IDH to enforce its rights. For example, IDH may disclose Profiles: (i) to appropriate authorities and to banks associated with a Subscriber’s and or Ad Partner’s Account in order to prevent or report suspected fraud and illegal activities; (ii) where it is necessary for IDH to enforce the applicable Subscriber or Ad Partner agreements; (iii) to resolve disputes, including disputes involving other Subscribers, Ad Partners or consumers, in connection with actual or potential parties to a lawsuit or actions that IDH is or may become involved in, and to identify potential liabilities and troubleshoot problems; or (iv) in order to prevent harm to any persons. In some cases, the government can compel the disclosure of information about a Subscriber or Ad Partner, and IDH will need to comply, in which case Subscriber or Ad Partner authorizes IDH to do so.

(c)  Storing and Processing Profiles. Profiles collected during a Subscriber or Ad Partner’s use of the Services may be stored and processed in any country in which IDH maintains facilities. Consequently, IDH has the right to transfer information (and maintain such information on computers) outside of a Subscriber’s or Ad Partner’s country, and you consent to such transfer. If a Subscriber or Ad Partner registers an Account on any website controlled by IDH or an IDH-related entity located outside of the United States, such Profile must be disclosed to IDH, which is located inside the United States, in order for the Subscriber or Ad Partner to access or use any IDH Services. Therefore, Subscribers and Ad Partners acknowledge and consent to the sharing, transfer and maintenance of their Profile with and by IDH and IDH-related entities worldwide.

(d)  Opt-Out. If a Subscriber or Ad Partner does not wish to receive communications from IDH as contemplated under this Privacy Policy, such Subscriber or Ad Partner has the ability to stop receiving these mail communications by logging into their Account and accessing the “Account Settings” screen in the IDH Site portal. Subscribers and Ad Partners will, however, always receive administrative emails from IDH that are related to IDH Services.

(e)  Interacting with other Users. PLEASE BE AWARE that when you use the Site or IDH Services to engage in activities with other Subscribers (for example, by posting information about yourself, communicating, interacting, corresponding, etc.), other Subscribers or IDH Ad users have access to that information. Hence, when you voluntarily post personally identifiable information or content to certain areas of the Site or through the IDH Services (such as to weblogs, message boards, classifieds, forums and other areas), or when you elect to engage in a transaction, communication or other conduct with another user through the Site or IDH Services, other Subscribers (and in some cases the public at large) can see, collect and use that information. The fact that the Site and IDH Services may permit you to communicate, interact with or link to other users is not an endorsement, authorization or representation of our affiliation with those users, nor is it an endorsement of their privacy or information security policies or practices. IDH does not exercise control over other users. Other users with whom you interact may place their own cookies or other files on your computer, and may collect data or solicit personally identifiable information from you. Such users follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to be careful how you interact with other users.

(f) Correcting/Updating Profile Information. Subscribers and Ad Partners can review, update and edit their Profile by logging into their Account and accessing the “Account” screen in the IDH Site portal and following the instructions posted.

(g) Transaction History. Subscribers and Ad Partners may unsubscribe from the IDH Services and request that IDH remove their Profiles from the IDH databases. However, in order to resolve disputes, assist with any applicable law, regulation, legal process or governmental requests or investigations, and due to technical constraints (including the fact that IDH backs up its systems), Subscribers and Ad Partners information and transaction history are never completely removed from the IDH databases.

6.   General:

Links to Other Sites. The Site and the Services may contain links to other websites. The fact that our Site and the IDH Ads permit you to link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. IDH is not responsible for, and does not exercise control over, the content, privacy or information security policies or practices of such other websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you and have different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Security. IDH is concerned with safeguarding your information. We employ a variety of industry-standard administrative, physical and electronic security measures designed to protect your information from unauthorized access. This includes encrypting certain highly sensitive personal information and storing it in limited access servers. Although IDH strives to keep information secure, no security measures are absolute or fool-proof, and there is always a possibility that a security breach could occur, resulting in the release of information. We will make any legally required disclosures of any breach of the security, confidentiality or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Business Transfers. IDH may sell, transfer or otherwise share some or all of its assets, including Profiles and information collected from you during your interaction with an IDH Ad, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. If any or all of the assets of IDH are acquired by, or merged with another entity, we will share some or all of the information described in this Privacy Policy with this entity.

Compliance with Laws and Law Enforcement. IDH cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you 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 IDH or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

Correspondence with IDH. If you contact IDH (or if others contact IDH regarding your activities), such contact information (including email and IP addresses) and the content of any communication will be collected and used by IDH in order to respond to the communication and send any relevant or requested information.

Our Policy Towards Children. The Site and Services are not directed to children under eighteen (18) years. We do not knowingly collect personally identifiable information from children under thirteen (13). If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at privacy@IdentifiedHits.com. If we become aware that a child under thirteen (13) has provided us with personal Information, we will delete such information from our files.

Contacting Us. If you have any questions about this Privacy Policy or the practices of this Site, you can contact us at: Privacy Officer, IDH Inc., 680 Mission St. #17E, San Francisco, CA 94105; or by email at: privacy@IdentifiedHits.com.