Privacy Policy

The Media Innovation Group, LLC is firmly committed to protecting the privacy of Internet users and fostering user confidence in the Internet, Internet advertising and direct marketing. Accordingly, we are committed to observing applicable industry guidelines, including those established by the Network Advertising Initiative and the Interactive Advertising Bureau. We continually evaluate innovative ways to protect online user privacy while also offering our clients the ability to own and use information regarding their interactions with their customers.

Our services and products are described at http://www.themig.com/technology.html#solutions ("Services"). The next few sections below describe how we collect user information in connection with the operation of our Services for or by our clients, such as through advertisements that may appear on various websites on the Internet. Certain information collected by the Media Innovation Group through the use of cookies used in the Services, as described below, may occur on numerous websites across the Internet.

This Privacy Policy applies only to the website on which it appears, and not to any other website or service. This Privacy Policy also provides information about activities we undertake across Internet websites on behalf of our clients.

For information on how we collect and use information that is collected directly from you on this website, please see the section entitled "Your Correspondence on this Website."

We do not collect Personally Identifiable Information.

We do not collect the online user's personally identifiable information ("PII") from users online through advertisements we manage on behalf of our clients. PII generally refers to information such as an individual's name, mailing address, phone number or e-mail address.

Non-Personal Information Collected by our Services

We do collect non-personally identifiable information ("Non-PII") to identify browsers that we have interacted with before. For instance, by using Non-PII, we may be able to identify a browser that has previously seen an advertisement we launched on behalf of a client. In the context of Non-PII, whenever we refer to 'you' or 'yours,' please remember that we may be referring to a certain browser and not an identifiable person since we generally do not know who is using a browser at any particular time.

Through the collection and use of Non-PII, we offer a range of Services to allow advertisers to show you the most useful and relevant online advertisements. You can learn more about these advertising practices by visiting http://www.iab.net/privacymatters/ or the "Learn More" section of the Network Advertising Initiative.

We may collect Non-PII regarding your online behavior and usage patterns through advertisements operated by our clients to better customize the type of advertisements you see on various sites. Non-PII consists of aggregated information, demographic information (i.e., the country from which you are connecting to the Internet) and other information such as the type of Internet browser used by an online user, a user's computer's Internet protocol ("IP") address, the type of computer operating system used, the domain name of the websites visited before and after viewing an advertisement, as well as information related to websites and web pages a user is viewing when an advertisement is shown which does not specifically reveal a user's identity.

We collect Non-PII through the use of cookies, pixels and related technology. No PII is collected or used in this process. A cookie is a file on your browser that uniquely identifies your browser and computer. A pixel is a line of code which is used by a website or third party ad server to track a user's activity. The use of a pixel allows us to record that a user has visited a particular webpage and to collect additional Non-PII that an advertiser may choose to request through the pixel. We may use cookies and pixels for planning, serving, analyzing and managing online marketing and advertising campaigns on behalf of our clients. Non-PII that is collected through our pixels, cookies and related technology will be retained for up to fourteen (14) months, at which time it will be purged from our system.

Though Non-PII does not personally identify anyone, we are still committed to giving users the opportunity to exercise choice about the Non-PII we collect.See the Section titled, "User Choice-Opting-Out of Receiving Cookies."

Sensitive Information

We do not knowingly collect or utilize sensitive information. Sensitive information may include information such as confidential or medical information, religious beliefs and other similar or related information.

Disclosure of Information to Third Parties

We do not collect PII via our technology and our client's advertisements, and therefore, we do not sell, rent, or share PII collected on through our Services with non-affiliated third parties.

We may disclose Non-PII collected through our Services, and information derived from it, to our clients, vendors and partners. This Non-PII may be used to deliver tailored ads to users on participating websites and for other purposes as described above. This information does not include any PII that can be used to contact or identify any person individually. Further, we encourage our clients, as applicable, to use any Non-PII they receive in compliance with applicable laws and regulations and to publish privacy policies that tell you about how the information they are gathering is being used. We urge you to always read the privacy policies of the websites you visit to understand issues relating to your online privacy.

We may disclose a user's Non-PII to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person. In addition, if permitted by applicable law, we may also disclose and provide access to a user's Non-PII to our vendors and contractors who are performing services on our behalf. However, such vendors and contractors are not permitted to use such user information for any purpose other than providing services to us.

User Choice - Opting Out of Receiving Cookies

We use technology, includes cookies and pixels, in the delivery of our Services. We believe that the use of these tools enables us and our advertiser clients to provide users with a more meaningful web experience.

At all times, you may adjust your computer's web browser settings to refuse all cookies. However, by doing so, you may not be able to enjoy or use certain features on the websites you visit or take full advantage of all the website offerings and interest based advertising. You can remove cookies by following directions provided in your Internet browser's "help" file.

You may also simply opt out of receiving customized advertisements provided by the Media Innovation Group and the collection of Non-PII in connection with the advertisements we manage on behalf of our clients. Of course, doing this means that you would no longer receive customized advertisements delivered through the Media Innovation Group's proprietary technology. To opt-out of our Non-PII collection, click here:

You can click on this link to the Network Advertising Initiative site to opt-out of receiving interest-based advertising from us and other NAI member company's or on this link to the Digital Advertising Alliance (DAA) to opt-out of our receiving interest-based advertising from us and other DAA member company.

Despite opting-out of our customized advertisements by following the process above, you may still receive tailored advertisements as a result of Non-PII collected by other parties not affiliated with, or controlled by us. To opt-out of receiving interest-based advertising from numerous other providers, including some of our partners, you can visit the website of the Network Advertising Initiative or the Digital Advertising Alliance to learn more and to make choices accordingly. Opting out does not necessarily delete or replace all cookies from our domain.

Our opt-out cookies are programmed to expire 10 years after they are initially issued. However, if you buy a new computer, upgrade or change web browsers or take any action which results in the deletion of this "opt out" cookie, you will need to perform this opt-out process again. In order for the opt-out to work, your browser must be set to accept third party cookies.

Data Retention

We may use our anonymous cookie information for advertising purposes for up to 14 months. Aggregate reports generated from this information may be kept longer.

Information Security

We follow generally accepted industry standards to protect against the unauthorized access to, retention of, and disclosure of information. This includes undertaking necessary physical, electronic, and management activities required to protect information integrity, access, and use. Any information that is stored on our server is treated as confidential information. Please keep in mind, however, that despite these reasonable efforts to protect information on our servers, no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect your information at all times, we cannot guarantee its absolute security.

Network Advertising Initiative

We are committed to following the Code of Conduct of the Network Advertising Initiative (NAI), of which we are a member. You can click the link below to reach the Network Advertising Initiative site, a central location for information about Internet advertising and the choices available to you and opt out of receiving interest-based advertisements from us and other NAI member companies.

Digital Advertising Initiative

We are also committed to following the Self-Regulatory Principles for Online Behavioral Advertising (Principles) released by the Digital Advertising Alliance in July 2009. You can click the link to reach the Digital Advertising Alliance site, a central location for information about Internet advertising and the choices available to you and opt out of receiving interest-based from us and other member companies: http://www.aboutads.info

Change to this Privacy Policy

Please note that because of the changing nature of privacy laws, user needs, and our business, we may modify this Privacy Policy from time to time by providing advance notice on our website before implementing such modifications. Accordingly, since we want to help you clearly understand our Privacy Policy, and any pertinent revisions, we encourage you to review our Privacy Policy periodically to become aware of any changes that may have occurred.

Information We Collect through Your Correspondence on this Website

If you provide us information through our "contact us" link on this website, sign up to receive our marketing emails or newsletters, submit information in connection with an employment inquiry, expressly enter information into a text field or otherwise submit information to us, we will keep a record of the information you provide including your email address and any other PII you provide solely for the purpose of responding to your inquiry or to provide you with requested marketing materials or newsletters. Except as set forth in this Privacy Policy, this information will never be shared with third parties without your consent. Media Innovation Group may pass your PII to our subsidiaries and affiliated companies so that they may contact you in connection with the objective of your inquiry. Where we pass your PII to our subsidiary or affiliated companies in another country, we will make sure that they apply the same level of protection to your information as we do. We may also disclose your information to third parties in the event of suspected fraud, legal requirement or in connection with our vendors and contractors, all as described above.

We also collect non-personally identifiable information from users who visit our corporate website in aggregate form to evaluate our corporate website usage such as the total number of visits to our Website, the number of visitors to each page of our Website, and the domain names of our visitors' internet service providers. Non-personally identifiable information may be collected using cookies. In addition, we gather information about visitors to our corporate website that is automatically collected by our Web server, such as your internet protocol address.

Children's Privacy

We are sensitive to the issue of children's privacy. Therefore, our website and Services are neither developed for, nor directed at, children. If you believe your child has provided us with PII, and you would like to have the information removed, please contact us at privacy@themig.com.

Linking to Other Websites

A link from our own website to another website does not imply our endorsement of that website. We do not control the websites to which we link and assume no responsibility for their content or privacy policies. Therefore, you should carefully review the privacy policies that apply to any websites you access from our website.

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 information (including any PII a user may have provided through the "contact us" page) that is in our possession or under our control to such acquiring party.

Data Storage - United States & United Kingdom

Our website and databases are maintained in the United States of America and United Kingdom. By using the website or our Services, you freely and specifically give us your consent to collect and store, your information in the United States and to use your information as specified within this Privacy Policy.

Spam and E-mail Lists

We do not intentionally send unsolicited e-mail messages that could be construed as spam.

A Special Note about the European Union

In compliance with the Safe Harbor Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact privacy@themig.com.

We comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/.

We have further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, 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 by us, you may contact:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: http://www.bbb.org/us/
Email: eusafeharbor@council.bbb.org

Questions or Comments about this Privacy Policy

If you have questions or concerns regarding this statement, you should first contact us through email. You can address your general questions and comments by e-mail to privacy@themig.com or by mail: Media Innovation Group LLC, 132 West 31st Street, 12th Floor, New York, New York 10001, Attn: Legal Department.

Updated: September 6, 2011