Privacy Statement

Effective Date: January 3, 2011

Proclivity supports the appropriate collection, use and protection of information and provides consumers with transparency about our practices and their choices.

Proclivity's Corporate Website

What information does Proclivity collect at its Corporate Website and what does it do with that information?

Proclivity, its service providers and other companies that work with Proclivity may collect non-personally identifiable information ("non-PII") about user visits to Proclivity's corporate website ("Visitor Data"). Such Visitor Data consists of clickstream information, such as IP address, browser used, and content clicked. Visitor Data is used to improve the Proclivity website, as well as offerings and promotion of Proclivity and others' products and services. In addition, we may also work with and share this information with third parties for analytic assessment of our Visitor Data and our site's performance.

Proclivity's corporate website does not collect personally identifiable information ("PII") unless visitors expressly and intentionally provide such information. In such instances, visitors to Proclivity's website may choose to provide Proclivity with PII, such as name, email address, geographic location and phone number, in order to request and receive additional information about Proclivity's products and services, or to inquire about a career opportunity. In such instances, Proclivity uses the information submitted to process such requests.

The Consumer Valuation Platform™ and Client Services

Proclivity operates a technology and analytics platform – the Consumer Valuation Platform, which it uses to provide certain data analytics and advertising related products and services to its clients ("Client Services").

What consumer information does Proclivity collect or access when it provides services to its Clients?

In order to receive Client Services, Proclivity's clients provide Proclivity with information about their customers. In addition, Proclivity uses JavaScript and pixel tags, cookies, or other technologies to collect information about consumers' interactions with the websites of advertisers, clients, publishers, partners or other content that Proclivity controls, manages or is authorized to access. (See "Proclivity Cookies and Pixel Tags" for more information) Proclivity may also work with third-party vendors to acquire additional information about consumers' preferences and interests. Together, this information includes non-PII, such as clickstream data, anonymous IDs, offline and online purchase activity, demographic and geographic information. Proclivity takes measures to exclude PII from its Platform, and to implement this approach, Proclivity uses programs designed to remove, block, de-identify or otherwise obfuscate PII, if any, before integrating incoming data into its Platform.

What does Proclivity do with information that it collects or accesses for Client Services?

Proclivity's Platform. Proclivity's proprietary system analyzes this information to develop insights about consumers' interests in order to deliver or enable clients to deliver relevant and targeted products, services and advertising or other content. In addition, Proclivity may also use this information to perform research and product development, measure performance, and generate reports, analytics and other assessments and insights that Proclivity may provide to clients or Proclivity may provide this information in anonymous or aggregate form to third parties for marketing, insights, research, product development, analysis and similar purposes.

Third Parties.

Proclivity may use third-party vendors to support the services that it provides to clients, which may require sharing information in anonymous or aggregate form. In those cases, such vendors are only authorized to use that information as designated by Proclivity for the purposes of providing services to Proclivity and its clients.

Data Retention.

Proclivity keeps the information that it collects or accesses from clients for as long as Proclivity maintains a customer valuation platform for that client or as required for legal compliance, archival or other related purposes.  Proclivity uses online behavioral data (specifically its valuation scores) for up to 2 years after the calculation of the score, after which Proclivity discontinues use for targeted advertising purposes and either deletes or archives the information for historical analysis or compliance purposes.

What choices do consumers have regarding Proclivity's collection, access or use of data for Client Services?

Our clients and partners determine, manage and are responsible for the privacy practices and choices available to their customers related to the information they provide Proclivity. For information that Proclivity collects directly from website users, Proclivity provides consumers the choice to opt out of the use of that information for interest based online advertising. See "Interest Based Online Advertising and Ad Choices" for further information.

Interest Based Online Advertising and Ad Choices

Why Interest Based Online Advertising and how do consumers benefit?

Advertising is a key part of the online experience because it supports the availability of content that consumers seek and enjoy. A goal of Proclivity's interest based online advertising services is to enhance the online experience for consumers by making those advertisements more relevant to their interests. To do so, Proclivity uses the information described above to develop insights that power the delivery of advertising about products and services intended to match consumers' interests.

In addition, Proclivity may also use information it collects to measure the performance of advertising campaigns and generate reports, analytics and other assessments that Proclivity may provide to clients or in anonymous or aggregate form to third parties.

What choices do consumers have regarding Interest Based Online Advertising?

Proclivity provides consumers the opportunity to choose whether to receive the benefits of interest based online advertising. If you do not want to receive interest based online advertising via Proclivity Cookies, click below to opt-out. If you choose to opt-out, Proclivity will deploy an opt-out cookie to your browser and will not serve interest based online advertising to you when you are viewing websites via that browser.  You may continue to see advertising, but that advertising will not be targeted by Proclivity to match your interests. Web users can also control cookies via their browsers, which can be set to limit, block or delete cookies. However, such browser changes may impact the effectiveness of the opt-out choice provided by Proclivity via an opt-out cookie, and consumers will need to repeat the opt-out process after changing browsers, computers or deleting their cookies.

In addition, consumers can find more information about interest based online advertising and their choices at the Digital Advertising Alliance.

Industry Engagement and Compliance

Proclivity supports industry efforts to protect consumers' privacy and provide them choices. As a member of the Network Advertising Initiative (NAI) and a participant of the Digital Advertising Alliance (DAA), Proclivity has committed to following their codes of conduct and principles to enhance privacy.

Proclivity Cookies and Pixel Tags

What are cookies and pixel tags?

Cookies are text files that web servers typically send to a user's computer when a user visits a website and that can be accessed by web servers when the user returns to a website or goes to another website. Cookies are used to collect and send non-PII about a user's visit to a website, such as pages viewed, time spent, and other statistics, and usually contain a string of anonymous, alpha-numerical characters. Pixel tags are small strings of code that are also commonly present when a user visits a website, and are often used to deliver images and transfer data about website interactions. Together these standard industry tools can allow website operators and their service providers to better understand a web user's interests and preferences, allowing them to provide more relevant information and advertising to users.

How does Proclivity use cookies and pixel tags?

Proclivity may deploy tags and drop cookies at the websites of advertisers, clients, publishers, partners or other content that Proclivity controls, manages or is authorized to access. Only Proclivity can access or write information to its cookies. That information is anonymous, for example, random numeric ids. Proclivity may also employ pixel tags. Through these tags Proclivity may access information such as pages visited, information browsed, products purchased, time spent on a site, and other statistics.

What choices are available?

Proclivity provides a choice to opt out of the use of its cookies to deliver targeted advertising. See "What choices do consumers have regarding Interest Based Online Advertising?" for more information. Web users can also control cookies via their browsers, which can be set to limit, block or delete cookies. However, such browser changes may impact the effectiveness of the opt-out choice provided by Proclivity via an opt-out cookie, and consumers will need to repeat the opt-out process after changing browsers, computers or deleting their cookies.

Information Security Proclivity has implemented security measures to protect information in its systems. Because no method of transmission over the Internet or method of electronic storage is 100% secure, Proclivity cannot guarantee absolute security.

Privacy of Children Proclivity is committed to protecting the privacy of children. Neither Proclivity's corporate website nor its services are intended or designed for children under the age of 13. Proclivity does not knowingly collect any personal information from a child under 13.

Other Sites Our site may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy policies before submitting any information, as these third-party sites are responsible for information that is submitted to, collected or used by them.

Additional Practices Proclivity may disclose information it has received or collected to comply with the law or in response to legal process, for example, a subpoena or court order. We may also transfer such information to corporate affiliates, or if we are acquired, sold to, or merged with another entity (including in the event of bankruptcy).

Contact Information For questions or concerns relating to Proclivity's privacy practices, please contact our representatives at the following:

By email: privacy@proclivitymedia.com

By mail:

Privacy
Proclivity Media, Inc.
33 West 17th Street
4th Floor
New York, NY 10011

Updates to Our Statement We may update our practices from time to time and will communicate those changes by updating this Statement.