Last Updated: May 23, 2018
Adelphic LLC (“Adelphic,” “we,” or “us”) operates an advertising platform that helps publishers and advertisers (our “Clients”) purchase advertising space, target audiences that are likely to be interested in relevant products and services, and understand how engaged the target audiences are in our Clients’ online advertising campaigns (the “Adelphic Service”). We generally do not collect information about consumers through our website www.adelphic.com (the “Site”), but we do collect other online and offline information about consumers’ interests and habits through web tracking technologies, and from our other business partners like data providers, ad exchanges, and mobile app attribution companies (our “Ad Partners”). We use that information to create audience segments that we make available to our Clients to enable them to deliver targeted, interest based advertising and to conduct analytics and research. The Adelphic Service delivers the targeted advertising messages to consumers (the “Users”) on computers, mobile phones and similar devices and enables us to report back to our Clients about the effectiveness of their advertising campaigns.
By partnering with us as Client, or visiting the Site and/or otherwise using the Adelphic Service, you agree to the terms of this Policy.
Some of the key topics you may be interested in include:
- Information you share with us
- Additional information we receive about you
- How and why we use, share, and disclose your information
- Children’s information
- How we secure your information
- How long we keep your information
- Cross-border transfers of information
- Recourse, privacy complaints by European Union and Swiss residents
- Additional privacy rights for California residents
- This Policy may change
- Contact information
- Key terms
I. Information You Share with Us
A. Personal Information That You Give Us
Adelphic generally does not collect personal information regarding individual Users through the Adelphic Service, and only via the Site when it is provided to us. In most cases, if and/or when we obtain personal information, it relates to our current or prospective clients and business partners. When we say “personal information,” we mean individually identifiable information that would allow us to determine the actual identity of and/or directly contact a specific living person, such as an email address or telephone number.
We collect personal information only when we are contacted directly by an individual through the Site and the individual voluntarily provides personal information to us, such as by submitting a question or registering to use the Adelphic Service. To the extent we receive personal information through our Site, we use personal information only in ways compatible with the purpose for which it was collected, such as to respond to email communications or questions, to facilitate registration for and delivery of the Adelphic Service, or for billing purposes. By voluntarily providing us with personal information, you are consenting to our use of it in accordance with this Policy.
II. Additional Information We Receive About You
A. Automatically Collected Information
The Adelphic Service collects information about your device and the ads that we deliver onto your device. This information, which is collected passively using various technologies, may come from such sources as your web browser or the apps that you use. We also obtain the precise location (e.g., latitude and longitude coordinates) of your device and may use that information to assist our Clients with targeting ads tailored to your interests.
We also combine the information collected across multiple sites and mobile apps in order to create interest segments that help us target future advertisements based upon those inferred interests. This combined information may also include whether you engaged with specific content or ads; and whether you went on to visit an advertiser’s website, downloaded an advertiser’s app, purchased a product or service advertised, or took other actions. This practice is sometimes referred to as behavioral advertising or interest-based advertising.
We use this information as part of the Adelphic Service to perform a variety of tasks, such as limiting the number of times a specific advertisement is presented to the same User (frequency capping), providing an advertisement to only certain types of Users, or providing a report to a client on the number of its advertisements that were clicked. We share this information with Clients, vendors, and other companies that we conduct business with as permitted by law. If you are located in the EEA, we will only collect, use, or share your information with our Clients for the purpose of serving you interest-based advertising if our Clients and Ad Partners have provided us with sufficient assurances that you have consented to receive interest-based advertisements. If you reside in the EEA, we do not allow our Clients to serve you ads based on your sensitive personal information, such as race, religion, political views, heath, biometric information, sexual orientation, or sexual activity.
Adelphic is a member of the Digital Advertising Alliance (DAA) and adheres to the DAA’s Self-Regulatory Program for Online Behavioral Advertising by respecting the DAA’s consumer choice tool for you to opt out of interest-based advertising. The DAA tool is located at https://optout.aboutads.info. Adelphic is also a member of National Advertising Initiative (“NAI”) and respects NAI’s consumer choice tool for you to opt out of interest-based advertising. The NAI tool is located at https://optout.networkadvertising.org. These tools enable you to opt of from receiving interest based advertising from many of our Clients and Ad Partners.
To opt out of receiving interest based advertising from Adelphic, click here and follow the instructions for web browsers and for mobile apps. If you opt out, we place an “opt-out cookie” to block the placement of Adelphic’s behavioral advertising cookies on your system for two years from the time you opt out. When we detect our opt-out cookie on your browser, we do not serve you with interest-based advertising on the browser or device from which you have opted-out, or on the browsers or devices that we believe are linked to your opted-out browser or device. However, if you delete your cookies or begin using a new browser or device, you will need to opt out again. Browser settings that block all cookies may prevent the opt-out from operating correctly and certain privacy software may delete the opt-out cookie or cause it to function incorrectly. Furthermore, the opt-out cookie is not effective on devices that do not accept or otherwise support cookies, such as iOS based mobile devices, internet connected televisions and other non-cookie based connected devices and applications.
For residents of the EEA, Adelphic is a participant in the industry-wide IAB Transparency and Consent framework which is designed to provide you with information about the legal basis for processing your personal information and let you know what companies are working with Adelphic and our Clients to process your personal information. You can access the list of participating companies and their privacy policies here.
B. Cookies and other Web Technologies
In operating the Adelphic Service and Site, we use a technology called “cookies,” which are small text files that our Site serves to your browser when you access the Site or that some of our Clients and Ad partners serve to your browser when you engage with them. Our cookies collect and store audience segments, help provide additional functionality to the Adelphic Service and Site, and help us analyze usage more accurately.
Although most web browsers automatically accept cookies, many browsers’ settings can be set to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some of our services may not function properly if you disable cookies. We do not support the Do Not Track browser option.
We also use an advertising identifier created by your mobile operating system to store information on our servers and later retrieve it to provide the Adelphic Service. The Android Advertising ID and Apple iOS’ IDFA are examples of advertising identifiers. For more information about advertising identifiers, please check the settings of your mobile device.
New technologies that perform similar functions may be developed. If we adopt new technologies that are not already described in this Policy, we will update it to let you know.
C. Log Data
We receive information when you view content on or otherwise interact with our Services, which we refer to as “Log Data.” For example, when you visit our websites, sign into our services, or interact with our email notifications, we may receive information about you. Log Data includes information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We use Log Data to operate our Services and optimize the performance of our Services.
D. Information from Our Clients, Affiliates and Ad Partners
Our Clients, ad partners, and affiliates share information with us such as browser cookie IDs, mobile device IDs, IP address, device type, operating system, hashed email address, or hashed mobile ID (e.g., Apple IDFA or Android advertising ID), as well as location-based data such as Wi-Fi, cell tower, GPS or diagnostic location information, contextual information, and demographic information including age, gender and zip code.
Information we obtain from these third parties (including our affiliates) about you may be appended to information that we otherwise have about you for the purposes of targeting advertisements. For example, we match hashed versions of mobile IDs to data that we have de-identified (made pseudonymous) about you that resides in our platform in order to target advertising to you based on your device activity, inferred interests and location information.
We use your appended information to create non-sensitive health and financial related interest-based segments as part of our services, including general interest-based segments such as “Health::Medical Centers” and “Finance::Insurance,” and custom interest-based segments such as “Health::Dieting::Acai Berry” and “Health::Contact Lens.” You may click here for a list of our general health and financial related interest-based segments. We do not use interest-based segments to determine credit worthiness or for insurance underwriting or employment eligibility purposes.
In the process of serving an advertisement to a device, we, or our partners, may decide to serve an ad based on one or more audience segments associated with that device, and the audience segment we believe may be associated with that device. Where Adelphic is able to use this and other information to infer that one browser or device likely belongs to the same User or household, the Adelphic Service may consider those browsers and devices “linked” for purposes of ad serving and interest based advertising. This linking process is sometimes referred to as creating a device graph.
III. How We Use, Share, and Disclose Your Information
This section describes how we share, use and disclose personal information in connection with operating the Adelphic Service and our Site. We do so with your consent, because it’s necessary to operate the Adelphic Service or our business, or because it’s required by law.
A. Managing Your Information
As described above, Adelphic uses the pseudonymous information we collect via the Adelphic Service and the information with combine it with from our Clients, affiliates and Ad Partners to create audience segments that are targeted to Users’ inferred interests. This information is typically associated with the advertising identifier referenced above and is used by us, our clients and partners, including advertisers and publishers, to deliver targeted advertising. As described above, you can opt out of receiving targeted advertisements from Adelphic and many of our Clients and Ad Partners at https://my.ipredictive.com/optout/, https://optout.aboutads.info and https://optout.networkadvertising.org. If you are located in the EEA, we will only collect, use, or share your information with our Clients and Ad partners, for the purpose of serving you interest-based advertising, if our Clients and Ad Partners have provided us with sufficient assurances that you have consented to receive interest-based advertisements.
When you opt-out of interest-based advertising through the Adelphic Service (as described above), we stop sharing your information with our Clients and Ad partners. That does not mean you will no longer receive advertising on the internet. However, it does mean that the display advertising you see will not be behaviorally targeted by us to your interests or preferences, so long as the opt-out cookie remains in place. Further, except for the specific restrictions noted above, our opt-out cookies do not otherwise prevent us from continuing to collect, maintain or use information as described herein, including for non-personalized advertising purposes (such as ad delivery and reporting) on your opted-out browser or device or on linked browsers and devices.
Data Subject Rights Applicable to Residents of the European Economic Area
If you reside in the EEA, you have additional rights in relation to how your personal information is processed. You may object to our processing of your data, request that our processing be restricted, review or request changes to your personal data, or request that your personal information be deleted and we erase your data by contacting us at Data Subject Rights Request Form.
You may also complain to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available at ec.europa.eu.
You may exercise any of these rights free of charge. However, we may charge a reasonable fee or refuse to act on a request if the request is manifestly unfounded or excessive, in particular because of its repetitive character.
Your privacy is important to us, so we will ask that you provide sufficient information to verify your identity before we respond to your requests. In some situations, we may refuse to act or impose limitations on your right if, for instance, it is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, or interfere with pending or future litigation.
For more information on your rights, please contact email@example.com.
B. Service Providers
We share your data with our service providers, including our contractors and business partners, who we engage to help us provide and manage the Adelphic Service, ensure network and information security, provide a more personalized experience, and analyze usage of the Site and the Adelphic Service. For example, we use Google Analytics, Google Tag Manager, and Yahoo Analytics to help us understand your usage of our Service, and partner with Aerospike to help us manage user data. Our service providers are located in the United States and other countries and we share your personal information with them subject to obligations consistent with this Policy and any other appropriate confidentiality and security measures, and on the condition that these third parties use your personal information only on our behalf and pursuant to our instructions. We share your information with our service providers to further our legitimate business interests of operating our business, and only do so after considering the potential impact to your individual rights.
C. Affiliates and Change of Ownership
We share your information within our corporate group, and particularly with our affiliates Viant Technology LLC, Viant US LLC, and Xumo LLC for uses consistent with this Policy, such as to help operate the Adelphic Service.
We may share, disclose, or transfer your information if Adelphic is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of Service to another provider, as permitted by law and/or contract.
D. Non-Personal Information
We share your non-personal information, such as aggregated information (in statistical or summary form that does not include any personal identifiers) with third parties in order operate and improve our service and conduct research about and analyze usage of our Services.
E. To respond to your requests based on your consent
If you interact with us on our Site or request information from Adelphic, we use and/or share your information, including any personal information you provide, to respond to your inquiries. We may also use your personal information to send your updates about our Services or changes to this Notice.
F. To Protect our Legal Interests
Additionally, we will use your personal information for other purposes permitted under this Policy, such as to protect or comply with legal rights and obligations.
There may be instances when we will use and/or disclose information we collect and receive where we have, in our discretion, a good faith belief that such use and/or disclosure is necessary in order to: (i) protect or defend our or your legal rights or property or those of our affiliates, employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of members of the public, including responding to emergencies where there appears to be a danger of death or injury to any person; (iii) comply with the law, law enforcement, or legal process or proceedings or requests from public or government authorities; (iv) prevent fraud or other liabilities.
IV. Children’s Information
We do not knowingly target advertisements to children. If you believe your child has been targeted by Adelphic with interest based advertising, please contact us at firstname.lastname@example.org to have the data provided by and associated with your child deleted.
V. How We Secure Your Information
Adelphic is committed to protecting the security of the information we collect. We use a variety of technical and organizational measures to protect information from unauthorized access, use or disclosure, both during transmission and once we receive it. We store your information on secure servers and encrypt it while in transit. However, no digital transmission or form of electronic storage is completely secure. Therefore, we cannot guarantee its absolute security.
VI. How long we keep your information
We store personal information such as email address, telephone number or billing details for so long as you continue to have a business relationship with Adelphic and for a reasonable time thereafter for record keeping purposes. We store pseudonymous identifiers, such as cookie IDs and mobile advertising ID’s collected via our Services, for as long as our systems are able to recognize a particular User, and for 90 days thereafter. We store log data for 90 days.
VII. Cross-Border Transfer of Information
We are a growing corporation with operations in multiple countries. We have developed data practices designed to assure information is appropriately protected. While our primary data centers are in the United States, where the laws of your country allow us to do so, you authorize us to transfer, disclose, store and use your personal data in the United States and any other country where we operate or engage service providers to assist us with our Services, consistent with this Policy.
For EEA residents, please be aware that the laws of the USA and other countries outside of the EEA may not protect your data to the same level as the laws of the EEA, or give you the same rights that you would have in the EEA (including right relating to access to personal data by law enforcement or national security/intelligence agencies). But when we transfer your personal data outside of the EEA, if the receiving country’s data protection laws do not offer the same level of protection as the laws of the EEA, we place contractual obligations (the EU Model Clauses) on the recipients of your personal data to ensure that your personal data is adequately protected. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Principles, respectively, Adelphic is potentially liable.
VIII. Recourse, Privacy Complaints by European Union and Swiss Residents
Adelphic has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Finally as a last resort and under limited circumstances, EU and Swiss individuals with residual complaints may invoke a binding arbitration option before a Privacy Shield Panel.
Adelphic is subject to the regulatory and enforcement authority of the United States Federal Trade Commission (FTC).
IX. Additional Privacy Rights for California Residents
Residents of the State of California may request a list of all third parties to which our Service has disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at email@example.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you – you need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
XI. Contact Information
For questions or concerns relating to privacy, please contact us at firstname.lastname@example.org.
880 Main Street
Waltham, MA 02451
EU Representative for purposes of this Policy:
- Embedded script
- Interest-based segment
- IP address
- Non-personal information
- Personal Information
- Server Logs
- Unique identifier
- User Panel
- Web Crawler
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
An embedded script is programming code that is designed to collect information about the way an advertisement displays on a website. The code is temporarily downloaded onto a user’s device from our web server or a third party web server, is active only while you are connected to a particular website, and is deactivated or deleted thereafter.
A user or group of users categorized on the basis of preferences or interests inferred from the data we collect and receive that are used as a basis for displaying advertisements and other content intended to be more relevant and useful to the user or users. Examples include “AUTO::Auto In-Market MASTER,” “TRAVEL::Travel In-Market MASTER” and “SPORTS::Sports Enthusiasts.”
Every computer connected to the internet is assigned a unique number known as an internet protocol (IP) address. Since these numbers are usually assigned in country-based blocks, an IP address can often be used to identify the country, and in many cases a more precise location, from which a computer is connecting to the internet.
This is information that you provide to us that personally identifies you, such as your name, email address, billing address and credit card information.
A pixel, also known as a pixel tag or web beacon, is a small snippet of code embedded in a website. Pixels allow a website to transfer or collect information through a graphic image request. Pixels can be used count site visitations and conversions, gather broad-based user interest data, transmit to and receive information from third parties, deliver, read and write to cookies and for other purposes connected to the provision of advertising, analytics or other services.
Like most websites, our servers automatically record the page requests made when you visit our sites. These “server logs” typically include your web request, IP address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
A unique identifier is a string of characters that is used to recognize a user’s device, browser or other platform. Unique identifiers may be used in conjunction with or separate from cookies, including on platforms (e.g., certain mobile devices) where cookie technology is not available.
Panel of internet users that agree to anonymous recording of their ad exposure activity as they browse the web and are exposed to video and display advertisements in exchange for free software and services such as browser toolbars, games, and applications that provide information services such as weather, travel, news.
A sophisticated bot that renders webpages as a user would in order to analyze the page content and how ads deliver to users on a given webpage.
Financial and Health Interest-Based Segments
- Finance :: Banking
- Finance :: Business Services
- Finance :: Credit Cards
- Finance :: Financial Information & Advice
- Finance :: Insurance
- Finance :: Mortgages
- Finance :: Personal Finance
- Finance :: Taxes
- Health :: Dieting
- Health :: Health Information
- Health :: Health Insurance
- Health :: Medical Centers
- Health :: Pharmaceuticals & Prescription Drugs