Last Updated: July 29, 2015
If you are a user of RightAction’s website located at the http://rightaction.com domain or our pureRTBTM Marketplace website located at the https://purertb.rightaction.com domain or any of the materials, products or services provided on or through those websites (collectively, the "Site"), or if you are one of RightAction’s Members and/or other third party who utilize the RightAction platform or services, you agree to this Policy, in its entirety, when you: (a) access or use the Site; (b) provide information through the "Contact Us" page of the Site; or (c) register on the Site to participate as an ad partner, supply partner, demand partner, or other customer or user of the RightAction Services (as this term is defined in the RightAction Website Terms and Conditions posted on the Site ("Terms")). If you do not agree to this Policy in its entirety, you are not authorized to become an ad partner, supply partner, demand partner, other customer, or an Individual member (collectively, a "RightAction Member") or to use the Site in any manner or form whatsoever. Additionally, this Policy is provided for informational purposes so that customers and users of RightAction’s Members can better understand how RightAction collects, discloses and uses personal information about them.
Our Policy is intended to explain our privacy practices concerning information about you, including:
- The kinds of information we collect;
- How we use information we collect;
- Disclosure of information we collect;
- How you can access, update and delete your personal information; and
- How we protect personal information.
Users of the Site and its products and services, and other persons who may be affected by RightAction’s advertising and Real Time Bidding ("RTB") operations, generally fall into the following categories:
1. Supply Partners;
2. Demand Partners;
3. Ad Partners;
4. Consumers who receive and/or interact with advertisements displayed by RightAction Members or their partners ("Individuals").
Information We Collect
The following is a summary of the types of personal and non-personal information we may collect from or about RightAction Members, Site users and Individuals.
RightAction Members and Voluntarily Provided Information. We collect personal information on the Site when you attempt to register as a RightAction Member or otherwise choose to provide personal information to us, such as through our contact form. Personal information is any information that can be used to identify or locate a particular person or entity. This may include, but is not limited to: personal name and business entity name and/or title with the applicable business entity, as well as your personal and/or business e-mail address, mailing address, daytime and/or mobile telephone numbers, fax number, PayPal or bank account information (including, but not limited to, account number, routing number and bank location), and/or any other information requested on the applicable RightAction Member registration form, such as username and password. (For purposes of this Policy, your bank account and other financial information shall be considered "Sensitive Information.") We also may collect certain non-personal information from RightAction Members, such as information typically contained in a web server’s log files or analytics program including: IP address, browser type, operating system, geographic location, referral information, click-stream data, etc. (for additional detail about these practices, please see the section below entitled "Individual and RightAction Member Behaviors Collected With Cookies, Web Beacons and Other Web Technologies.") Finally, we may collect server and Individual activity information so that we can provide our products and services to RightAction Members.
Individuals: Subscription or Survey Information. RightAction or RightAction Members may collect information from Individuals when you voluntarily provide it to RightAction or one of its RightAction Members (for example, by signing up for an email newsletter or through a co-registration offer on a survey), or by other means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a "User Form"). In a User Form, RightAction or a third party may offer you incentives in exchange for providing information about yourself, such as name, email address, street address, zip code, telephone numbers, birth date, gender, salary range, education and marital status, occupation, employment information, and personal and/or online interests (together, "User Information")). Completing the User Forms is voluntary and you are under no obligation to provide User Information.
You may set your browser to warn you that cookies are in use, or to block the use of certain cookies. Most browsers are set to accept cookies. If your browser is not set to accept cookies, certain uses of the Site may require you to go to your browser user preferences to enable cookies. Each browser is different, so check the ‘‘Help’’ menu of your browser to learn how to change your cookie preferences. If you change computers, operating systems or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser.
(b) Web beacons. A web beacon is a programming code used to display an image on a web page and can also transfer an individual’s user identification to a database and associate the individual with previously acquired information about the individual. Web beacons may be used by us to track certain websites you visit or content you view online. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes.
(c) Where Technology Information is Collected. Technology Information may be collected directly from the Site or indirectly through RightAction Members with whom RightAction contracts.
(d) Outside Information. RightAction may lawfully receive information about you from third parties, such as information located in public databases.
(e) No Information Collected from Children Under 13. Please be advised that we do not knowingly solicit or collect personal information from children under age 13, nor do we knowingly market our products or services to children under age 13. If we become aware that a child under age 13 has provided us with personal information, we will delete it from our database. If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us at privacy@RightAction.com.
How We Use Your Information: RightAction Members
We use your personal information primarily for administrative purposes pertaining to your account and customer management purposes, including: (a) processing payments; (b) providing reports, customer service, newsletters, RSS feeds and other information, products, or services that you have signed up for or have otherwise agreed to receive; (c) operating the Site and the RightAction Services; (d) sending you information regarding the Site or the RightAction Services; (e) displaying content that is customized to your interests and preferences; (f) tracking with your compliance with the Terms, and any other applicable agreements such as the RightAction RTB Marketplace Agreement, as applicable; (g) contacting you when necessary regarding your account with us and/or operational updates to our Site; and (h) for validation, suppression, content improvement and feedback purposes. We may also send you surveys and marketing communications to inform you of new products or services or other information or offers that may be of interest, and/or updates about RightAction. These surveys, marketing communications, or updates may come from RightAction or our service providers. If you do not wish to continue to receive surveys, marketing communications or updates, you may indicate this preference by following the "unsubscribe" or "opt-out" instructions included within each email communication, or by other written request to RightAction. Please keep in mind that, even if you choose not to receive these communications, you may continue to receive transactional or account communications (e.g., confirmation emails) and other communications which are required or permitted by applicable law.
We use Sensitive Information only to process, and provide support, servicing and fraud detection for, payments and other transactions that RightAction Members have requested.
You also agree that we may also use your name, company name and logo in advertising or promotional materials to refer truthfully to you as a partner of ours or as a RightAction Member in the RightAction network.
We use non-personal information primarily for internal research and analytics to improve our Site and our Services.
How We Use Your Information: Individuals
Certain of our partners may use your information to ensure that the advertisements they serve are targeted and are interesting to people who see the advertisements. For example, they may aggregate demographic data to create anonymous groups so that they can serve advertisements, which may appeal to members of those groups. They may also use Technology Information to associate an individual with their information, and attempt tto show advertisements and content for products and services to which the individual may respond. When advertising targeting options are available to and utilized by our partners, RightAction may pass through such information between its partners in providing the RightAction Services.
Disclosure of Your Personal Information
We do not sell, rent, lease or disclose your personal information collected by the Site to unaffiliated entities, except in the limited circumstances listed below. RightAction may transfer or disclose information to our affiliated entities, that is, entities that control, are controlled by, or are under common control with RightAction, for marketing and other purposes at our discretion.
We may disclose your personal information to third-party service providers who perform services on our behalf. For example, we may engage other companies to handle the processing of payments, to provide data storage, to assist in marketing RightAction’s products or services, to conduct audits, to provide web analytics, and to provide hosting, design, development and other operations which make our Site work. Other third-party service providers may help us communicate with you through electronic mail, direct mail or telephone communication. Our policy is to permit these third-party service providers to obtain only the personal information they need to provide the services, and to require them to protect personal information to the same extent as RightAction, including not using it for any improper purpose.
We may also make your personal information available to non-affiliated third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary under the following circumstances:
- When we are compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or other legal process);
- If we believe your actions violate any law, regulation, our Terms, the RightAction RTB Marketplace Agreement, or any other agreement by which you are bound, or if you threaten the rights, property or safety of RightAction, the Site, our service providers, suppliers, customers or users, or any other party;
- If we believe such disclosure to be necessary or appropriate to investigate or resolve possible problems or inquiries, to protect our business and assets, to defend our interests and/or to comply with our legal and regulatory obligations;
- To cooperate with law enforcement authorities, a court or administrative agency, or other governmental authority in connection with an investigation or where otherwise required or permitted by applicable law; and
- In the event of a bankruptcy, merger, acquisition, transfer of control, joint venture, sale of assets or other strategic business transaction or event involving us and/or our related companies.
Disclosure of Non-Personal Information
In addition to the foregoing, RightAction may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons. For example, we may provide our RightAction Members with aggregate, anonymous non-personal informational about Individuals, including, without limitation, demographic data. This aggregate data allows us to create anonymous groups that our partners use to identify business opportunities.
Accessing/Updating/Deleting Your Personal Information
If you would like to delete or update the personal information that we have collected from you, simply send your request via e-mail to privacy@RightAction.com. If you are a RightAction Member then you may update your personal information by logging into your account at our Site and modifying your account information. We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extreme impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
To unsubscribe from RightAction or RightAction Member email lists, click the link included in the footer of any message delivered by RightAction or a RightAction Member and follow the instructions provided, or contact us in writing.
Notwithstanding the foregoing, even if you unsubscribe from marketing emails, we may continue to contact you for the purpose of communicating information relating to your participation in the RightAction pureRTB marketplace or use of the RightAction Services, as well as to respond to any inquiry or request made by you.
How We Protect Your Personal Information
We know it takes confidence and trust to share personal information online. We endeavor to keep your confidence and maintain your trust by protecting your personal information. To that end, we maintain reasonable standards of security and confidentiality. RightAction’s computers have security measures, such as firewalls, to protect against the loss, misuse and/or alteration of the information under RightAction’s control. RightAction also maintains physical and procedural safeguards to protect information under our control and to restrict access to those employees and agents who have a need to know in order to provide services to you and/or operate our business. We also rely as much as possible on reputable third-party payment solutions in connection with processing payment transactions that may involve Sensitive Information.
Notwithstanding such measures, RightAction cannot guarantee that its security measures will prevent its systems and computers from being illegally accessed and the Individual information on them stolen or altered. Despite our efforts, as with most Internet sites and businesses, it is possible that third parties may unlawfully intercept or access transmissions of private communications and/or unlawfully gain access to protected computers. No method of data collection, transmission or storage is 100% secure, and we cannot warrant such absolute security. Whenever you provide personal information online, you accept this risk, including when you share your personal information with us and our RightAction Members.
Notwithstanding these inherent risks, we make a concerted good faith effort to ensure that your personal information is protected by maintaining the reasonable standards of security and confidentiality mentioned above.
Privacy Practices of Third Parties
Third Party Web Technologies. RightAction Members in the RightAction pureRTB marketplace, as well as other partners and advertisers who place advertisements on the Internet or provide Ad Units or Ad Inventory, may use their own cookies, web beacons and other Web Technologies to collect information about you. RightAction has no control over or responsibility for third parties’ use of such Web Technologies.
Links to Third Party Websites. The Site, RightAction Member’s web properties, and e-mail messages transmitted by RightAction on its own behalf or on behalf of its RightAction Members may contain links to third-party websites ("Third Party Websites"). Please be aware that RightAction is not responsible for the privacy and security practices of Third Party Websites. We encourage you to be aware when you leave the Site (or when you leave a RightAction Member’s web property) and to read the privacy policies of each and every website that you visit. This Policy applies SOLELY to information collected by RightAction or the Site.
If you have any questions regarding this Policy, or would like more information on our privacy practices, please contact us at privacy@RightAction.com.