Privacy Policy
24/7 Real Media, Inc. is firmly committed to protecting the privacy of Internet users and fostering consumer confidence in the Internet, Internet advertising and direct marketing. We continue to focus on innovative ways to protect online user privacy while also offering our clients the ability to own and use the data regarding interactions with their customers. We invite you to review the overview of our Privacy Policy and our more detailed Privacy Policy set forth below. Please note that because of the changing nature of privacy laws, consumer needs and our business, we may modify this Privacy Policy from time to time without the consent of users by providing advance notice on our Web site before implementing such modifications. Accordingly, since we want to help you clearly understand our Privacy Policy, and any revisions to our Privacy Policy, we encourage you to review our Privacy Policy periodically to become aware of any changes that may have occurred. We also invite you to contact us at privacy@247realmedia.com with any questions or concerns.
The purpose of this privacy policy is to inform you of what kinds of information we may gather about you when you visit a site powered by 24/7 Real Media ad serving technology and services, how we may use that information, when information may be disclosed to anyone, and the choices you have regarding whether and how we gather and use information related to you. While this privacy policy applies to the global operations of 24/7 Real Media, Inc., including its operations in Europe under European domain names, we will refer here only to 24/7 Real Media to make reading this policy easier. Finally, please note that this policy applies only to 247realmedia.com, except where specifically stated otherwise below.
1. We do not directly collect personal information.
We do not directly collect personally identifiable information ("PII"). PII generally includes information that could be used by us to determine the identity of an online consumer, such as name, address, phone number and email address. You should note that we do not have the ability to prevent our clients from using our technology to collect PII about users of their Web sites. For example, some of our clients may use our technology solutions in conjunction with an e-commerce system where providing PII is necessary to complete a transaction. We require our clients to comply with applicable laws governing online privacy and encourage them to publish privacy policies that tell you about how the information they are gathering is being used. We encourage you always to read the privacy policies of the Web sites you visit to understand issues relating to your online privacy.
We may collect non-personally identifiable information ("Non-PII") to help our clients better determine which advertisements or content to show or not to show you. Non-PII may include information such as the type of Internet browser used by an online user, the type of computer operating system used and the domain name of the Web site visited by the user as well as information related to Web sites and Web pages a user is viewing when an advertisement is requested, the location of the user’s Internet service provider’s point of presence, the date and time of a visit to a Web site, search keywords passed from another server, the number of times a user has clicked on an advertisement or other interactions between a user and a Web site.
2. Our Technology Solutions employ cookies to gather Non-PII.
(A) Internet Ad Delivery and Management.
Generally, when you see an ad served by 24/7 Real Media on a Web site, we have been hired by a client Web site to provide services including ad delivery, reporting or analysis of certain usage statistics on their Web site, as well as general system monitoring or error reporting. In connection with providing these services, we employ cookies under our Internet domains, such as 247realmedia.com, to more effectively serve our clients and help them better determine which advertisement to show or not to show you. We serve a unique cookie for each customer. In the process of delivering an advertisement, we automatically recognize certain Non-PII that is linked to a particular cookie. We only use data collected via our cookies for purposes authorized by our client.
(B) Audience Management and Web Analytics.
We employ cookies and action tags under our Internet domains, such as 247realmedia.com, when clients use our audience management Web analytics products and services. Typically, when you visit a Web site that uses our analytics application or our related technologies, we have been engaged by our client Web site to provide services for reporting or analysis of click-stream or other user activity relating to that Web site, as well as general system monitoring or error reporting. The information we process on behalf of such client belongs to that client. We only use that information for purposes authorized by our clients.
(C) Behavioral Targeting.
We provide data analysis and audience segmentation services based on information provided by our clients regarding their customer interactions, including those on the client’s Web site. We create usage/behavior/interest-based categories called "segments." Segments are unique groups of users that are created using criteria that enable the client to selectively serve targeted advertisements or content and otherwise profile users of that client’s Web site(s). We are an outsourced solution for what many companies traditionally have done internally, including traffic pattern and behavioral trend evaluations to enhance the usability and marketing power of their Web sites. In connection with providing these services, we employ cookies under our Internet domains, such as 247realmedia.com, or in the client’s domain to better define segments and determine which segments an online user belongs to. We serve a unique cookie file for each customer. In the process of defining segments with respect to online users, we automatically recognize certain Non-PII that is linked to a particular cookie. We do not use any of the data collected via our unique cookies for commercial purposes not authorized by our client.
(D) Search Marketing.
We may employ cookies when search engine marketing clients use our services and technology. Typically, our Decide DNA™ platform and our related technologies are used by a client advertiser to provide services for bid management, reporting or analysis of performance-based search marketing campaigns as well as general system monitoring or error reporting. With the exception of aggregate performance metrics, the information we process on behalf of such client belongs to that client. We only use that information for purposes authorized by our clients.
(E) Opting Out.
You can opt-out of 24/7 Real Media ad delivery, audience management, behavioral targeting and search marketing cookies by following the instructions set forth below under "How Can You Opt-Out of 24/7 Real Media Cookies?" To opt out of a particular client’s cookie, please visit the Web site of that client.
3. We encourage all companies with which we do business to engage in fair information practices.
We request that our clients acknowledge and comply with the standards of online privacy, as outlined by the Online Privacy Alliance www.privacyalliance.org. Also, in accordance with the Network Advertising Initiative (NAI) www.networkadvertising.org, we require our clients to create privacy policy statements and to provide Internet users with conspicuous access to their privacy policy statements. Additionally, we require that our clients disclose any and all information that is being collected from Internet users on their Web sites, including data gathered from banners and other forms of advertising, as well as content delivered or other transactions occurring on their Web sites. Although we cannot monitor every transaction tracked by each of our many clients and match it to each respective client’s privacy policy, we periodically monitor the Web sites of our clients to determine whether they are adequately disclosing and updating their privacy statements.
4. The promises we make about information you give us online should be upheld.
We may change our privacy policy as new products are added or old ones are changed, but we endeavor to treat information we possess (including information collected from this Web site), in a manner consistent with the policy under which it was collected. If part or all of our assets or business operations are acquired or otherwise transferred, we will take steps to assure that these same principles continue to apply to the acquiring company.
5. Questions and Concerns.
You can address your general questions, concerns, comments and complaints to privacy@247realmedia.com. 24/7 Real Media is also an associate member of the Network Advertising Initiative located online at www.networkadvertising.org.
24/7 Real Media, Inc. is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to build users’ trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the site http://www.247realmedia.com. Because we want to demonstrate our commitment to your privacy, we have agreed to disclose our information practices and have our privacy practices reviewed for compliance by TRUSTe.
If you have questions or concerns regarding this statement, you should first contact our legal department at legaldepartment@247realmedia.com. If you do not receive acknowledgement of your inquiry or your inquiry is not satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.
24/7 Real Media, Inc. complies with the European Union Safe Harbor Principles regarding the collection and use of personal information obtained from the European Union and is a member of the European Union Safe Harbor Framework. If users feel we are violating the Safe Harbor Principles, they should contact us at legaldepartment@247realmedia.com. If contacting us does not resolve the complaint, users may contact BBBOnline at http://www.bbbonline.org/consumer/complaint, an independent group we have retained to provide dispute resolution for disputes that arise regarding our compliance with the Safe Harbor Principles. If BBBOnline finds us to be in violation of the Safe Harbor Principles, we will correct the situation and stop processing the data of the user bringing the complaint.
HOW IS DATA COLLECTED USING OUR TECHNOLOGY AND SERVICES?
24/7 Real Media provides technology and services that allows Web publishers and advertisers to serve advertisements, manage audience relationships and understand how consumers are using their Web sites. 24/7 Real Media’s patented ad serving technology is the Open AdStream Platform used by our client advertisers and Web sites and the Web Alliance, our online media network. Analytics applications inherent in Open AdStream allow our clients to determine the number of visitors, their most popular content, and the number and type of transactions on their Web sites. We use unique "cookies" that enable our clients to more effectively use our services to build relationships with their online customers.
What Are Cookies?
Cookies are very small computer files delivered to a user’s computer, by or on behalf of our clients, when that user’s Internet browser views one of our client’s advertisements. Cookies are associated with a specific computer and a specific Internet browser. You can think of a cookie as a file containing a note saying, "This Internet browser was here at this time." It tells our clients that a user’s Internet browser has viewed a client’s advertisements at a specific time. Cookies delivered by us, on behalf of our clients, do not include your name, address, phone number, email address or other PII. The cookie contains a unique number assigned to your Internet browser to tell our clients that they’ve seen that browser at a Web site where they advertise. Typically, when our clients hire us to deliver ads on their behalf, we assign a cookie to every user who visits a Web site where a client’s ad is displayed and where a Web beacon (see discussion below) is placed. We also may use cookies to limit the amount of times you see a particular ad.
What Are Web Beacons and Action Tags?
A Web beacon, or action tag, is a piece of HTML code that can be placed on a Web page. When your Internet browser loads that page, a request is made to a server. This works exactly like requesting any page on the Internet. The major difference is that instead of the content of a page being returned to your browser, the server sends a clear GIF (Graphics Interchange Format) image. These GIFs are often called "one-by-ones" because it is only one by one pixel in size and often appears invisible because it is so small. Typically, Web beacons are created using HTML (HyperText Markup Language) tags in Web page code. We employ Web beacons on Web sites, on behalf of our clients, to help them analyze and measure the effectiveness of advertising campaigns and the general usage patterns of visitors to their Web sites. For example, when a user clicks on an advertiser’s Internet ad, the user is taken to the advertiser’s Web page. If the advertiser chooses to employ a Web beacon, the advertiser’s Web page will contain a clear GIF image that is not visible on your screen. Our clients typically use Web beacons to collect Non-PII about your visit to a particular Web site. This Non-PII is sent to the client ad server to help better determine which ads to show you.
How Can Users Block Cookies?
One way you can stop cookies from being stored on your computer, and therefore, stop Web sites and advertisers from storing and using certain Non-PII collected about you, is to block all cookies by disabling cookies in your Internet browser configuration. This will block cookies from our clients and everybody else. Depending on your Internet browser, you can block all cookies in the following way:
Microsoft Internet Explorer 6.x
1. Menu: Tools-Internet Options
2. Select Tab: Privacy
3. Pull "slider" to "Block All Cookies," which is the highest setting
Netscape Navigator 4.x
1. Menu: Edit-Preferences
2. Select Category: Advanced
3. Find section: Cookies
4. Select your choice
How Can Users Delete Cookies?
One way you can delete cookies stored on your computer, and therefore interrupt the process by which Web sites and advertisers collect Non-PII about you, is to delete all cookies on your computer’s hard drive. This will delete cookies from our clients and everybody else. Depending on your Internet browser, you can delete all cookies in the following way:
Microsoft Internet Explorer 6.x
1. Menu: Tools-Internet Options
2. Select Tab: Settings
3. Select Tab: View Files
4. Select and delete the cookies you want to delete from your hard drive.
Navigator 4.x
1. Menu: Edit-Preferences
2. Select Category: Advanced
3. Find section: Cookies
4. Select your choice
Please consult the user manual or help file for your particular browser for any changes to the above process.
WHAT DATA IS COLLECTED USING OUR TECHNOLOGY?
We May Collect Non-Personally Identifiable Information (Non-PII)
We may collect non-personally identifiable information ("Non-PII") to better determine which ads to show you. Non-PII may include information such as the type of Internet browser used by an online user, the type of computer operating system used and the domain name of the Web site visited by the user as well as information related to Web sites and Web site sections a user is viewing when an advertisement is requested, the location of the user’s Internet service provider’s point of presence, the date and time of a visit to a Web site, search keywords passed from another server, the number of times a user has clicked on an advertisement or other interactions between a user and a Web site.
Specifically, when an Internet user visits a Web site where one of our client’s advertisements is displayed, cookies and Web beacons are delivered under the domain of our client, to help our clients collect Non-PII about the user’s visit. Our technology, including our analytics application, is also capable of collecting content variables based on such pages visited and the time of visit. We help our clients collect information about how many times users view and click on our clients’ advertisements and whether or not a user visits specific pages of a client advertiser’s Web site (e.g. a registration or checkout page). In doing so, we may collect the user’s IP address, Internet browser type and version as well as the type and version of their computer’s operating system and, in some cases, keywords entered into search engines. We also may cross-reference IP addresses with databases maintained by our vendors to generate general location information about IP addresses.
Sometimes our clients will send us Non-PII they collected online during transactions so that we can provide targeted advertisements and analyze if our advertising has resulted in sales. We may also help our clients collect information on events that occur on a client’s Web site, such as when the user has registered to receive information. Generally, in these situations, we do not know the specific content of such transactions, but only that the event occurred.
We Do Not Directly Collect Personally Identifiable Information ("PII")
We do not directly collect personally identifiable information ("PII"). However, a client may be able to use our technology to collect a variety of information, including PII. We also may be asked by a client to collect PII on its behalf using cookies and Web beacons. We use information provided by the client, as well as information that we collect on behalf of the client, only to create segments and reports for the client. Additionally, we make information that we collect or receive from a particular client available only to that client. A client may correlate or merge information that we report to it with PII already collected or accessible by that client from sources that do not include us. On behalf of a client, we may correlate information provided by the client with Non-PII that we collect for that client. Our clients are responsible for notifying you whether they correlate or merge PII to Non-PII that they collect or that we or any other third party collects on their behalf. Our clients represent to us that they comply with applicable laws and industry standards regarding online privacy.
WHAT DATA IS COLLECTED THROUGH THE 24/7 REAL MEDIA WEB ALLIANCE?
24/7 Real Media provides advertising services to companies that have Web sites and to companies that wish to advertise on the Web. One way of selling advertising for Web sites is to group together sites that have a similar "content" (such as golfing or sports sites) or similar segments (types of visitors) in order to serve the same ad across multiple small sites. We call these groups of sites "networks" and sell advertising on these Web sites. Other larger, Web sites may stand alone and operate independently with respect to advertising sales on their sites. Our 24/7 Real Media Web Alliance comprises our network which includes brand-name sites and niche sites that provide advertisers with a broad "reach" by attracting many different Internet users, and other larger, branded Web sites with whom we have relationships.
We employ cookies and Web beacons under our Internet domains, such as 247realmedia.com, to collect anonymous information relating to the activity of users that view ads and content on the 24/7 Real Media Web Alliance. These are used for creating profiles we call segments. We employ cookies and Web beacons primarily to: (i) report to 24/7 Real Media’s advertiser and Web site clients the estimated total reach of an ad campaign; (ii) report the frequency with which an ad was shown to a user and other measurement statistics; (iii) ensure that an ad displayed to a user corresponds to the correct click-through destination; (iv) deliver a series of advertisements in the proper sequence; (v) limit the number of times a browser is delivered the same advertisement; and (vi) make a more informed decision about what ad to deliver to a user. In addition, we do not merge PII with Non-PII or otherwise parse, sort, gather or aggregate user data for our commercial use elsewhere.
We request that Web site publishers belonging to the 24/7 Real Media Web Alliance consent to and comply with the standards of online privacy, as outlined by the Online Privacy Alliance. Also, in accordance with the Network Advertising Initiative (NAI), we strongly encourage all Web sites within the 24/7 Web Alliance to create privacy policy statements and to provide Internet consumers with conspicuous access to their statements. Additionally, we request that all Web site publishers doing business with us disclose any and all information that is being collected from Internet consumers on their Web site, including data gathered from banners and other forms of advertising being served on their Web site. Finally, we encourage Web sites in the 24/7 Real Media Web Alliance to provide links to all advertisers gathering information from Internet consumers in their respective privacy statements.
Please note that our Privacy Policy applies only to our operation of the 24/7 Real Media Web Alliance and not to the operations of Web sites with which we may do business. We encourage you to always read the privacy policies of the Web sites you visit. If you have particular concerns about any Web site advertising with 24/7 Real Media with respect to privacy issues, please contact privacy@247realmedia.com.
How Can You Opt-Out of 24/7 Real Media Cookies?
To uphold our commitment to online privacy, we offer you the choice to "opt-out" of 24/7 Real Media cookies to prevent any data from being associated with your Internet browser. Following the opt-out process, you will continue to have a 24/7 Real Media cookie on your computer, but, for our purposes, it will contain only an "off switch" used merely to tell us not to write a new cookie of that type on your computer. When we see this "off switch," we will know not to attempt to assign other such cookies to you in the future and we will not collect any additional information from your use of the Internet. Since the opt-out cookie does not contain a unique user ID number, it does not allow us to identify your browser uniquely.
Please keep in mind that your election to opt-out of certain 24/7 Real Media cookies will not be effective until you delete the related opt-out cookie on your computer’s hard drive. Further, if you have elected to opt-out of certain 24/7 Real Media cookies or you have blocked all cookies in your Internet browser configuration, we won’t be able to recognize your computer from one visit to the next. As a result, you may see the same ad multiple times or receive more ads that are not of interest to you. Also, if you change computers, have different browsers, have different computers, update your Internet browser or delete your cookie, you should repeat this opt-out process. Please note that you may configure security features of your Internet browser to block all or some cookies, including third party cookies, such as 24/7 Real Media cookies. In the event that your browser is configured to block third party cookies, you may not be able to effectively opt-out of 24/7 Real Media cookies. Please refer to the section entitled "How Can Users Block Cookies?" above.
Also, please note that some cookies are delivered under the domain name of one or more of our clients. In the case of these cookies, we are not in a position to provide an opt-out feature. We encourage you to always read the privacy policies of the Web sites you visit.
If you would like to be opted-out of 24/7 Real Media ad delivery, audience management and behavioral targeting cookies, please click here. If you would like to be opted-out of 24/7 Real Media search marketing cookies cookies, please click here.
WITH WHOM DO WE SHARE COLLECTED INFORMATION?
We may share information collected about Internet users with our clients only in accordance with these privacy policies. Other than with respect to information specific to a client, we do not collect or sell the ownership of PII or Non-PII for our own commercial purposes. From time to time, we may publish or report aggregate statistics related to our business. When we report or publish such statistics, we do not include or reveal any information about users.
The anonymous information that we collect on behalf of our clients is useful only to the specific advertisers who employ us to deliver ads, and only in the context of our selection of ad-content and our reporting of ad-effectiveness to our client. In order to assess an advertising campaign’s effectiveness, our clients may hire us to report to them our analysis of the anonymous data in a summarized format. On occasion, our clients ask us to send them, or their agents, our anonymous data that is collected on their specific Web site. In these situations, we send only anonymous data. We recommend that you visit our clients’ Web sites to review their privacy policies and contact them directly if you have questions about their information practices. Some of our clients, or their agents, might receive anonymous information relating to Web traffic behavior from us. Our clients typically warrant that the information they receive shall be used in compliance with applicable laws and regulations. We recommend that you visit our clients’ Web sites to review their privacy policies and contact them directly if you have questions about their information practices.
We may also disclose certain information in response to subpoenas, court orders or legal process.
WHAT DATA IS COLLECTED ON THE 24/7 REAL MEDIA WEB SITE?
We may use cookies, Web beacons and log file information (such as Internet Protocol Address, referring URLs, etc.) about your activity at this site in order to understand Web site usage and enhance your experience at this site. For example, if you choose a certain language version of this site, when you return to the site we will recognize your cookie and automatically display the site in the language you requested. Information about those cookies or Web site usage is not combined with cookies by our clients or by our Web site nor is information about the cookie or log file information linked with PII, if any, you may have provided at this Web site. In addition, we may serve ads on this Web site. In doing so, our ad server will place or read a unique cookie on your computer and will use Non-PII about your browser and your activity at this site to serve ads to you. You may be asked to provide PII in certain fields on this Web site to better help our staff respond to your inquiries. The PII collected on this site is used only for the purpose for which it is requested, and will not be processed in a way that is incompatible with that purpose:
1. Contact information for potential clients or persons seeking business information may be collected by us in order to contact that person to provide information about our services. Such information is usually deleted as space requires or in the normal course of business, but can be amended or deleted upon request. To review, amend or delete your information, contact privacy@247realmedia.com.
2. Contact information, such as your name, address, telephone number or email address, for consumers, investors or customers with questions, concerns, complaints, inquiries, requests for information or technical support questions, may be used to respond to your request for information. Such information is usually deleted as space requires or in the normal course of business, but can be amended or deleted upon request. To review, amend or delete your information, contact privacy@247realmedia.com.
3. Upon submitting your information to us, you will receive an automatic confirmation email. You do not have the ability to opt-out of this one-time confirmatory email.
4. We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
If all or part of the 24/7 Real Media Web Alliance or our company is acquired or otherwise transferred to another entity, any PII you have provided at this site may be transferred as part of that transaction. However, we will take steps to assure that such PII, if any, is used in a manner consistent with the privacy policy under which it was collected. Other than agents who act on our behalf, PII you provide at this site will not be transferred to unrelated third parties, unless we have your permission to do so. However, please note that PII provided to us in connection with this site is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. We may purge from our databases any information (whether PII or Non-PII) about users of our Web site without notice to any user.
WHAT POLICIES GOVERN SECURITY AND ACCESS TO COLLECTED INFORMATION?
We maintain strict data security systems that ensure specific information will not be made available to any unauthorized person and in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Our employees are made aware of and are accountable for compliance with our privacy policy. Any information collected by us on behalf of our clients is stored on our Web server or database but is not publicly accessible from our Web site or otherwise. We use a multi-level, password protected security system to control access to information stored about users. We also maintain strict physical security of our properties and facilities and only provide access to authorized personnel.
HOW ARE DISCLOSURE AND CHANGES TO 24/7 REAL MEDIA’S PRIVACY POLICY MADE?
We publish our privacy policies and practices at www.247realmedia.com/EN-US/privacy-policy.html. Any material change to our privacy policy will be conspicuously noted in our privacy policy, which is accessible from our main Web page at www.247realmedia.com. In addition, users may contact us at privacy@247realmedia.com with any further questions or concerns. Users may also contact us in writing at 132 West 31 Street, New York, New York, 10001 , Attention: Legal Department.
WHERE CAN YOU GO FOR MORE INFORMATION?
For more information about 24/7 Real Media, Inc., please contact us at info@247realmedia.com. Please email questions or requests for more information about 24/7 Real Media’s privacy policies to privacy@247realmedia.com.
CAUTION REGARDING LINKED WEB SITES:
This Web site contains links to other Web sites. We are not responsible for the privacy practices or the content of such Web sites. We encourage you to read the privacy statements of these linked Web sites, as their privacy policies may differ from ours.
WHAT ARE SOME OTHER PRIVACY RESOURCES? The following is a list of selected links to privacy-related resources that can be found on the World Wide Web:
Center for Democracy and Technology
http://www.cdt.org/privacy/
Department of Education: Parents Guide to the Internet
http://www.ed.gov/pubs/parents/internet/index.html
Federal Trade Commission
http://www.ftc.gov/privacy/
National Telecommunications and Information Administration
http://www.ntia.doc.gov
Network Advertising Initiative
http://www.networkadvertising.org
Online Privacy Alliance
http://www.privacyalliance.org
Privacy.org
http://www.privacy.org
Last updated February 1, 2008
