Privacy Policy

Effective Date: November 28, 2012

ACSENCION LLC and our wholly-owned subsidiaries (collectively “ACSENCION LLC” or “we”) respect and value your privacy. As such, we have created this Privacy Policy for our online advertising exchange line of business (referred to in this policy as “Ad Exchange”), which is a service we provide to other businesses to help advertisers reach their target audiences and website publishers monetize their site traffic.

As we help advertisers and website publishers, we also create value to individual online end-users, by delivering personally relevant advertisements. Ad Exchange does not collect or use any personally identifiable information (“PII”) (such as name, contact information or address) from end-users in the course of serving advertisements. Below, we describe our practices as they relate to the use of the non-personally identifiable information we collect in the course of ad delivery.

Ad Exchange reserves the right to modify this Privacy Policy from time to time. Changes to the Privacy Policy will be posted on this website and the effective date of the Privacy Policy will be modified to reflect the effective date of the most recent version. If a material change to our information practices occurs in the future, we will only use information collected from the time of the policy change forward for these new purposes unless we have your consent.

Ad Exchange does collect PII from our website publisher and advertiser customers in the context of business-related dealing or inquiries. This Ad Exchange privacy policy applies only to the non-PII collected about individual website end-users for Ad Exchange services, through cookies, pixels and other tools as described in more detail below.

WHAT NON-PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT AND HOW WE USE IT
Ad Delivery & Reporting
Ad Exchange does not collect any PII about individual website end-users (such as your name, email address, etc.). With each advertisement served (known as an impression), Ad Exchange collects information such as the time of day the impression occurs, the specific URLs visited by end-users, and the end-user’s browser type, browser language, and IP address. That information is used to verify our records, to provide our customers with additional ad-related services such as statistical reporting about website activity and the number of ads served, and to provide more relevant services to end-users, such as showing relevant ads to end-users based on the specific website URL, or page, visited. Displaying an ad relevant to the content on the web page visited is commonly referred to as contextual advertising. We may also provide information to other entities such as what specific ads an end-user was exposed to.

Targeting Advertisements
Many Ad Exchange ad impressions involve contextual advertising. As mentioned above, these ads are generally targeted to content categories only, meaning that an end-user sees a particular advertisement based on the type of content found on the page that user is visiting. Other times, our technology considers anonymous information such as the time of day or approximate geographic area of the end-user in order to deliver advertisements that are more relevant to that individual end user.
Ad Exchange also engages in online behavioral advertising (OBA). This involves using patterns of online behavior observed by Ad Exchange or its third-party data partners to segment users into interest groups for advertising campaigns. These processes are carried out using cookies and pixels. “Cookies” are small pieces of information that are stored by your web browser on your computer when you visit. Pixels are small graphic images (usually invisible) that can be embedded in content and advertising on a website, which can be used to recognize our cookies and to monitor certain user interactions with the website.
The information contained in the cookie is recognized by Ad Exchange and is collected for targeting purposes at the time of the ad impression. For example, an advertiser might work with Ad Exchange to reach people who have recently visited the advertiser’s website. A cookie is placed on an individual’s web browser while on the advertiser’s site, and when that cookie is seen by Ad Exchange on the site of one of our publishers, we deliver the advertiser’s message. Similarly, if an advertiser wants to reach individuals who have expressed purchase intent for a category of products, Ad Exchange may serve advertisements relevant to that category of products to individuals with third-party cookies on their browsers that reflect that intent.

Ad Exchange may also use other information obtained from third-party data partners that reflects or suggests the end-user has a higher likelihood of being within a certain de-identified segments of the population. These de-identified segments, which may include de-identified health segments, may be based on demographic characteristics such as age and gender, geographic area and other categories derived from various information, including purchasing tendencies. During no stage of this process does Ad Exchange know the identity of the end-user.

ACSENCION LLC complies with the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (DAA). As part of this service, all Ad Exchange advertisements that are delivered using behavioral data are delivered with the Advertising Option Icon, which helps consumers understand how their data are being used and provides choices for consumers who want more control.
We are committed to following the Code of Conduct of the Network Advertising Initiative (NAI). In accordance with the NAI code of conduct, we require our website publisher clients to provide conspicuous access to their privacy statements.

In order to provide increased transparency around advertising regarding health related segments, we offer information regarding all of the consumer segments that we may use for health by clicking here.

CONSUMER CHOICE
We offer the choice to opt out of Ad Exchange behavioral advertising. Opting out does not prevent end-users from seeing Ad Exchange ads; it simply means that you will no longer receive ads that are relevant to your historical viewing interests, personal characteristics or consumer segments. You will still receive contextual ads, as described above. Our opt-out tool follows:

COOKIE TARGETING ALLOWED OPT-OUT
The NAI’s opt-out tool also allows you to opt out of the data collection and targeted ad programs of ACSENCION LLC. You may access the NAI opt-out tool here. PrivacyChoice’s opt-out tool allows you to opt out of other third parties who may place cookies on your computer. To opt out of these third parties, please go to http://www.privacychoice.org/choose.
Our opt-out tool, and the NAI opt-out tool, are cookie-based. Both opt-out tools only prevent us from collecting data pertaining to you on the browser on which they are installed and will only function if your browser is set to accept third-party cookies. If you delete an opt-out cookie from a browser’s cookie files, we may collect data and place a new cookie unless an opt-out cookie is reset on that browser. PrivacyChoice offers both a bookmark and browser plugin that can make your opt-out choices more durable.

Additionally, you may prevent us from collecting data on a browser by blocking third-party cookies in that browser. If you block third-party cookies from being set on your browser, you may not be able to enjoy some features or functionality of, and you may see the same content and advertisements repeatedly on some websites.

INFORMATION SHARING
ACSENCION LLC may share non-personally identifiable Ad Exchange information we maintain in a de-identified form with advertisers, business partners, sponsors and other third parties. For example, we may make information about the end-user viewing each impression available to buyers and potential buyers of such impression or we may disclose how frequently the average Ad Exchange end-user requests pages about a certain category (such as health or finance), or which advertisements a particular end-user interacts with on domains across our exchange.

There may be disclosures or transfers of any and all types of information held by ACSENCION LLC or Ad Exchange under the following circumstances: 1) in the event that all or most of ACSENCION LLC’s assets are acquired by another company; 2) in the event of our bankruptcy, insolvency, reorganization, receivership or assignment for the benefit of our creditors; 3) if we determine it necessary in connection with an investigation or in order to enforce our legal rights; or 4) to comply with any valid legal process such as a search warrant, subpoena, statute or court order. In addition, we may share your non-personally identifiable information with subcontractors, vendors and other businesses that we employ to perform functions on our behalf. For example, we may employ third parties to analyze data or provide marketing assistance. These entities have access to your information only for the purposes of performing the functions for which we have engaged them.

This Privacy Policy applies only to information gathered by Ad Exchange. Except to the extent that third-party cookies are used by Ad Exchange for advertising purposes, the privacy of end-users with respect to third-party pixels and cookies on websites end-users visit, is described by those websites and other third parties’ privacy policies, not ours. Ad Exchange is not responsible for the privacy practices of such third parties.

DATA RETENTION
Non-personally identifiable data may be stored by Ad Exchange for up to 18 months. Aggregated data concerning usage patterns of advertisers and publishers within the self-service portal will be retained for a period longer than 18 months.

SECURITY
ACSENCION LLC makes reasonable efforts, consistent with industry standards, to protect all of your data in its possession. However, no method of transmission or storage is 100% secure and ACSENCION LLC will not be responsible for any damage that results from any security breach of data.

OTHER INFORMATION
Advertising Content
End-users, publishers and advertisers alike should understand that ACSENCION LLC has no control over the content presented in advertisements served on our exchange, the products or services advertised or the pages linked to in those advertisements. This content is provided by third-party advertisers and ACSENCION LLC will not be responsible for any third-party content, advertisements, products, services or websites.

Children
In the interest of the privacy of children, Ad Exchange does not offer advertising packages aimed at reaching end-users under the age of 13. Our website and services to advertisers and publishers are neither developed for nor directed at children.

Ad Exchange European Union Residents
ACSENCION LLC has self certified to the Department of Commerce’s Safe-Harbor framework, and we adhere to the Safe-Harbor Principles. For more information on the Safe-Harbor program, visit http://export.gov/safeharbor.

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