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EXPONENTIAL INTERACTIVE, INC.
PRIVACY POLICY

Updated on October 15, 2010

Exponential Interactive, Inc. ("Exponential") is a technology-enabled media services company whose clients and customers include both online advertisers ("Advertisers") and Internet content sites ("Publishers"). We deliver innovative products and services designed to:

    • enable Advertisers to better reach their target audiences; and
    • enable Publishers to support, grow and monetize their websites through the sale of advertisements.

Our product offerings and services currently include Tribal Fusion, FullTango, EchoTopic and LeadGenuity (together, referred to herein as our "Services"). For a full description of these Services please see our website at www.exponential.com.

At Exponential we believe that safe, secure and respectful practices regarding the use of consumer information are fundamental to our business success and to the growth and vitality of the Internet as a whole. We are a member of the Network Advertising Initiative ("NAI"). We maintain compliance with the NAI's Self-Regulatory Principles and IAB UK's Good Practice Principles.

This Privacy Policy is intended to provide consumers with clear and complete information about the consumer data we collect in connection with our Services and the way that data is stored and used by our company, our Advertisers and our Publishers. For information about our privacy practices as they relate to our corporate website, please see below.

Information We Collect

Non-Personal Information Collected by our Services
We deliver advertisements from hundreds of Advertisers across a multitude of Publisher websites. When you visit one of the Publisher websites in our network, our automated system may collect "click stream data" related to your visit to the website. Click stream data is anonymous and can include information such as your IP address, Web pages viewed, the date and time at which those pages were viewed and interaction with content and advertisements on those Web pages. Technologies used to collect this click stream data, include cookies and Web beacons. For a description of cookies and Web beacons see our FAQ section. Our anonymous cookies are programmed to expire in six months.

In order to improve performance, we augment our click stream data with non-personally-identifiable behavioral and demographic data from Publishers and other partners. This anonymous data may include such things as zip code, age, gender and income range.

We utilize the non-personal information described above to better customize the sort of advertisements you see. We also aggregate anonymous cookie data in order to identify large audience segments that assist advertisers in targeting their campaigns to the most relevant Internet audience. We store the information collected in log files, and log files are retained in our systems for a reasonable period of time. Anonymous data stored in our log files that associates the log data to a particular computer include IP address and User ID. We purge the IP address and irreversibly obfuscate the User ID from our log files six months after collection of this information.

Consumer Choice - Opting Out of Receiving Cookies
We use technology which includes cookies and web beacons in the delivery of our Services. We believe that the use of these tools enables us to provide users with a more meaningful web experience. You may adjust your computer's web browser settings to refuse all cookies. However, please note that because cookies are widely used, disabling the use of cookies in your web browser may interfere with full use of various websites.

You may opt out of receiving Exponential cookies by clicking here


You can also opt out of receiving cookies from Exponential and other NAI member companies by clicking here


Through this opt-out procedure, your computer will request an "opt-out cookie" ID tag that will prevent your anonymous data from being matched to your computer and thereby prevent us from using that data to deliver targeted advertising or other content to your computer's browser. Please note that this opt-out process will erase the cookie ID associated with your computer but not the cookie itself - the cookie itself must remain on your computer in order for us to recognize you as an opt-out user. This means that if you use multiple computers or multiple browsers you will need to opt out of receiving cookies on each computer and for each browser. Also, if you change computers or delete cookies from your computer you will need to repeat this opt-out process.

Personally Identifiable Information Collected By Our LeadGenuity Service
LeadGenuity helps marketers reach potential customers who are interested in receiving information about their products or services. In response to a marketer's advertisement, you may choose to provide personally identifiable information such as your name, address, telephone number and/or email address. Exponential will not merge any of this LeadGenuity personally identifiable information with any non-personally identifiable information collected by our systems (including systems for all other Exponential divisions) and will not use this personally identifiable information in any way that is not authorized by the marketer for whom it is collected. In addition, we keep this data in a separate database to preserve our guarantee that advertisements are delivered only through the utilization of anonymous consumer data.

Personally Identifiable Information Collected Through Our Corporate Website
You may also provide us with personally identifiable information (such as your name, email address, physical address or telephone number) when you elect to contact us about this Privacy Policy or any other customer-service related matter. We will only utilize such personal information for the purpose of responding to your inquiry. However, we do reserve the right to retain an archival record of all such correspondence.

We reserve the right to disclose personally identifiable information you have disclosed to us in response to judicial process or court order or to provide information to law enforcement agencies or in connection with an investigation of matters related to public safety, as permitted by law.

International Transfers of Data
Personally identifiable information collected by Exponential on its own behalf or on behalf of its LeadGenuity clients may be stored and processed in the United States or any other country in which Exponential or its affiliates, subsidiaries, agents or customers maintain facilities. You acknowledge and agree that personally identifiable information you provide to us may be transferred outside of the country in which you reside. Providing such information will constitute your consent to any such transfer.

Information Security
Exponential follows generally accepted industry standards to protect against unauthorized access to, destruction or disclosure of data. This includes undertaking necessary physical, electronic and management activities required to protect data integrity, access and use. Any data that is stored on our servers is treated as confidential and is not made generally available to the public. Our servers are protected by firewalls and are located in secure data facilities to further increase security. Please keep in mind, however, that despite these reasonable efforts to protect data on our servers no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect your personal data at all times, we cannot guarantee its absolute security and shall not be liable for any breach of security by an outside party.

Transfer of Data Upon Change of Control
In the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, asset purchase or other transaction, we reserve the right to transfer all data (including any personally identifiable data) that is in our possession or under our control to such acquiring party.

Children's Privacy
Exponential is sensitive to the issue of children's privacy. Hence, our services are neither developed for, nor directed at, children. We don't offer the targeting of advertising towards anyone under the age of 13.

Healthcare Privacy
Exponential allows advertisers to target users in certain health-related categories. A list of these categories may be found here

Changes to this Privacy Policy
We reserve the right to make changes to this Privacy Policy by posting an updated version on this page. The date on which the current Privacy Policy was posted will always be noted at the top of this page. Any change we make to our Privacy Policy will be made in compliance with applicable law.

Correspondence
If you contact us, we may keep a record of that correspondence, including your email address. This relates to your correspondence with us only - we do not gather users' email addresses as part of our online advertising business.

We are committed to following the IAB UK Good Practice Principles. If you feel we are breaching those Principles, you should contact us at privacy@exponential.com. If contacting us does not resolve the complaint, you should follow the IAB UK complaint procedures at www.youronlinechoices.co.uk/how-do-i-make-a-complaint.

Questions and Comments
Questions and comments regarding this Privacy Policy should be directed to privacy@exponential.com or mailed to:

Exponential Interactive, Inc., 2200 Powell Street, Suite 600, Emeryville, CA 94608, Attn: Legal Department.

 
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