Services Privacy Policy

LAST UPDATED: July 14, 2011

In the course of providing services to our customers, we, IgnitionOne, Inc., may collect, use and disclose information, and we want you to be familiar with how we collect, use and disclose information through our IgnitionOne analytics and web customization services (the "Services"). This Privacy Policy does not address the collection, use or disclosure of information by any other means; if you wish to understand our practices with respect to information we collect via our website, please review our IgnitionOne General Privacy Policy . We reserve the right to change this Privacy Policy. You can determine when this Privacy Policy was last revised by referring to the "LAST UPDATED" legend at the top of this page.

Our customers are the operators of third party websites that you may visit and with which you may interact. We provide our customers with the Services, which help them understand your interactions with their websites. Our customers value these insights so they can improve their websites and better serve your needs. To generate our reports for our customers, we monitor how you use their sites at our customers' request and on their behalf. Because we undertake these activities for our customers, you should also consult our customers' privacy policies to learn more about their practices.

Non-Personal Information is information that does not reveal your specific identity. We and our third party service providers may collect Non-Personal Information from you in the course of providing the Services to our customers, including by placing cookies and using technologies sometimes referred to as "pixel tags," "web beacons" or "clear GIFs." To enable the Services (such as our reporting service), we place cookies on your computer that associate a unique identifier with your web browser (or we recognize cookies placed by an affiliate). These cookies may originate either from our domain name or the domain name of an affiliate (sometimes called third party cookies) or, if requested by our customer, from our customer's domain name (sometimes called first party cookies). We use a variety of methods to place our cookies, including:

- Inbound Redirects. Our customers promote their websites (such as through search engine advertisements) using URLs that do not lead directly to the customer's website. Instead, the customer codes its URL so that you first visit a URL we operate but that you won't see. When you visit our URL, we place the cookie. Our URL then automatically sends you to your destination URL on the customer's website.
- Web Beacons. When you visit a page incorporating our web beacons, it initiates a connection with our servers at the same time it delivers our customer's web page to you. At that point, our servers may place a cookie on your computer.

Although customers usually incorporate our web beacons only into the websites they operate, sometimes they make arrangements to incorporate our web beacons into third party websites. In these cases, we will record your interactions with these third party websites on behalf of our customer. We recommend that you check our customer's privacy policy for more information about where they incorporate our web beacons. When our web beacons are incorporated into third party websites, all references in this privacy policy to our customers' websites include these third party websites as well.

For more information about our affiliates, you should review the privacy policies of the companies listed at http://www.innovationinteractive.com/affiliates.html.

Once we have placed cookies with our unique identifier on your web browser, our customers ask us to monitor your interactions with their websites and collect Non-Personal Information in connection with the same. We may do this monitoring in a variety of ways. For example:

- Web Beacons. Our customers use web beacons to allow us to monitor your interactions with their websites. We can also use web beacons to facilitate third party cookie placements as directed by our customers. In some cases, we can monitor some of your interactions with websites not operated by our customers through inbound redirects (which are discussed in more detail above).
- Outbound Redirects. When you follow links on our customers' websites, our customers may direct you to visit a URL we operate but that you won't see. By delivering this URL to you, we can record some information about your activity. We will then automatically redirect you to your destination URL.
- Unique ID. In some cases, we inform our customers of the unique ID number we have assigned to your computer. These customers may associate this unique ID number with the other information that we have provided to them, and then provide us with other information about your interactions with the customer's site (including, potentially, Personal Information about you). Please note that any Non-Personal Information that is associated with Personal Information will be treated by us as Personal Information by us as long as it is so combined. Please consult the customer's privacy policy to learn more information about their practices with respect to the unique ID we provide to them, as well as with respect to their use and disclosure of your Personal Information.

As you navigate our customer’s website, we keep track of your activity on that site using the cookies and web beacons. Our database of past user website interactions makes some predictions about your interests, As you navigate our customer’s website, we communicate our predictions to our customer, and the customer may choose to use those predictions to modify the web pages it presents to you accordingly.

We use Non-Personal Information to provide reports to our customers. Except as described in the Personal Information section below, our reports generally summarize multiple users' activities and do not usually include any Personal Information, so it would be unlikely for a customer to learn anything specific about you or your activities through the reports generated by us. Please note that, because Non-Personal Information does not personally identify you, we may use Non-Personal Information for any purpose. In addition, we reserve the right to share such Non Personal Information, which does not personally identify you, with customers, affiliates and other third parties, for any purpose.

IP Addresses. Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever users visit the Site, along with the time(s) of such visit(s) and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP addresses for purposes such as calculating usage levels for our Services and for our customer websites, providing our customers with geographic-specific reporting, helping diagnose server problems, and administering the Services. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information. Please note that we treat IP Addresses, server log files, computer IDs and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.

Personal Information is information that identifies you as an individual, such as your name, email address, postal address, telephone number and/or fax number. We do not generally collect Personal Information through the Services; however, we may receive Personal Information in connection with the Services if one of our customers chooses to provide it to us or if one of our customers ask us to create a page with a form you can use to voluntarily request additional marketing information from the customer (“Request Form”). If you choose to complete a Request Form, then: (1) we will transmit the information from the Request Form to the customer who requested the information; (2) we may simultaneously communicate our predictive assessments about your interests; and (3) we may retain a copy of the information in your Request Form. We retain any Personal Information we receive from a Request Form in a separate database from our other information about you, so we do not use Request Form information to predict your interests. We seek to suppress Personal Information in the Request Form database no more than six (6) months after the Personal Information was added to this database. Please note that in the course of obtaining Non-Personal Information, we do incidentally record the URLs you visit, and Personal Information can occasionally appear in those URLs and thus be incidentally stored in our database. We use Personal Information for the purposes for which it was provided, to respond to our customers' requests, for our internal business purposes (for example, for data analysis, audits, developing new products, improving our services, identifying usage trends and determining the effectiveness of promotional campaigns) and as otherwise required or permitted by law.


We may disclose Personal Information to our customers who provide us with Personal Information (in some cases, combined with Non-Personal Information that we have collected, as noted above), for example, when we provide reports to our customers. Please note that we are not responsible or liable for the use of your Personal Information, or any other information, by our customers.

We may also disclose Personal Information to our service providers to enable them to provide services and to our affiliates so that they may use such Personal Information for the purposes described in this policy. IgnitionOne, Inc. is the party responsible for the management of the jointly-used Personal Information.

Further, we may disclose Personal Information to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). Finally, we may disclose Personal Information as we believe to be appropriate: (a) under applicable law including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.

Security. We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.

Opt-Out. You can opt out of our Services as follows:

- a customer may enable you to opt-out of its tracking via a page on its website.
- you can turn off your cookies permanently or you can turn off your cookies temporarily on your browser when you visit our customers' websites. Note, however, that turning off cookies, permanently or temporarily, may impair your ability to fully experience a website's offerings.

Changing or Suppressing Personal Information. If you would like to change, suppress or otherwise limit our use of your Personal Information that has been previously provided to us, you may contact us by sending an email containing your request to privacy@ignitionone.com. For your protection, we will only implement such requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity and/or obtain more information from you before implementing your request.

In each event, you must clearly indicate the information that you wish to have changed, or suppressed or clearly indicate the limitations you wish to put on our use of your Personal Information. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. We are not responsible for changing or suppressing information in our customers' databases.

Retention Period. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Customers participating in our Services can each individually determine how long we retain server logs associated with their websites, so please check their privacy policies for more information. If a customer does not specify a retention time, we seek to keep that customer’s customization-related server logs for no more than six (6) months. With respect to Request Forms, we seek to retain that information for no more than six (6) months.

Jurisdictional Issues. Please be aware that due to the international nature of our business, Personal Information may be transferred to countries outside the country in which you reside, including to the United States, which may provide a different level of data security than in your country of residence.

Contacting Us. If you have any questions regarding this Privacy Policy, please contact us by email at privacy@ignitionone.com, or please write to the following address or fax number:

Legal Department
IgnitionOne, Inc.
32 Avenue of the Americas, 5th floor, New York, NY 10013
Fax: 212.703.7276

Please note that email communications will not necessarily be secure; accordingly you should not include credit card information in your email correspondence with us.