Web User Privacy Policy

Last updated February 27, 2013

Welcome to Commission Junction, Inc. (hereinafter "Commission Junction", "CJ", "we" or "us"). All references to "Commission Junction", "CJ", "we" or "us" in this Privacy Policy shall refer only to Commission Junction, Inc.

At Commission Junction, privacy is a top priority and we provide this Privacy Policy to outline our practices and procedures with respect to information collection and use to enable you to make an informed decision about sharing information with us. Commission Junction is an advanced performance marketing solutions company, and we may deliver and/or work with advertisements delivered to the websites you visit or via other marketing channels.

All other ValueClick, Inc. entities are governed by separate privacy policies found on such entities' respective websites. Commission Junction is a subsidiary of ValueClick, Inc., and ValueClick, Inc. is a member of the Digital Policy Forum, which works to address important privacy and consumer protection issues in emerging media.

INTRODUCTION

Acceptance of Terms
Please read this policy carefully because by visiting this website or domain or other Commission Junction Websites or domains ("Website") and/or sharing information with us, you agree to be bound by this Privacy Policy. The Privacy Policy may be revised or updated at any time by us. This page was last updated as of the date at the top of this Privacy Policy.

Summary
We have included a table summarizing our practices solely for your convenience and reference purposes. This table, however, is not an exhaustive description of our privacy practices and should not be construed to define, limit, and/or describe the scope or extent of our Privacy Policy. As a result, we urge you to read the entire Privacy Policy. You may click on the terms to the left of most of the summaries below to link to more information.
 

Information NOT Collected - PII

We do not collect personally identifiable information (data collected with an intention to identify and/or contact a person such as name, address, telephone number or e-mail address) (hereinafter "PII"), except as expressly provided for herein. PII may be collected should a consumer contact Commission Junction on his/her own initiative or respond to a Commission Junction advertisement and provide such PII.

Information Collected - Non-PII

The non-personally identifiable information we collect may include as an example, IP address, browser types, operating systems, domain names, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity.

How Information is Used

We may use your Non-PII ("Information") for the following general purposes: enhancement of our services; marketing; and to more effectively match advertisements and website content to your interests.

Sharing Your Information

We may share your Information with third party service providers we have contracted with, ValueClick, Inc., and its subsidiaries and affiliates ("Value Click Entities"), third party marketing partners, business partners and our clients, and as expressly provided for herein.

Your Choices

You may regulate the use of cookies and the associated collection of your Information through your browser settings.

Security

We use reasonable and appropriate security measures to protect your data.

Changes

We may change the Privacy Policy at any time by posting the revised Privacy Policy on the Website along with the date such Privacy Policy was last updated.

Contact Us

If you have any questions about this Privacy Policy, the practices of or your dealings with us relating to this Privacy Policy, please email us at cjprivacy@cj.com or send correspondence to us at the following address:
Commission Junction, Inc., Privacy Officer, 30699 Russell Ranch Road, Suite 250, Westlake Village, CA 91362.

INFORMATION WE COLLECT

Non-Personally Identifiable Information
As part of our on-going efforts to ensure the best possible experience for all recipients of Commission Junction advertising, we may use log files, web beacons and cookies (defined below) to collect and store data from browsers, advertiser and third party sites ("Sites") to aggregate Information. The Information collected is used for marketing purposes, enables us to determine which advertisements perform well, allows us to more effectively match advertisements and website content to your interests, if necessary, assists us in improving the operation of our services, helps us to maintain the quality of our services, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding use of Commission Junction's services.

"Log files" store tracked actions occurring on Sites and collect data including your IP address, browser type, referring url, request url, user agent, browser accept language, platform type, and date/time stamp (for clicks and sales/leads only), which make up click, impression, and sales/lead data, advertisements viewed, and any other data that comes from interaction with Commission Junction's network.

"Web beacons" are objects that are embedded in a web page or e-mail and are usually invisible to the user but are used to track a web user's navigation of a website or collection of websites or pages, interaction with an e-mail, the completion of transactions, submittal of applications and browsing behavior.

"Cookies" are files (e.g. flash browser objects or http header) that are stored on your web-enabled client (such as your web browser). There are many misconceptions about Cookies, some of which we will try to address in this policy. Cookies cannot erase your hard drive or otherwise damage your computer and do not tell us an e-mail address or any other PII. Commission Junction does not and cannot use Cookies or web beacons to retrieve PII from your computer. Cookies are used to improve the experience web users have when they see web advertisements. When a consumer responds to or views an Internet advertisement served by Commission Junction (such as through third-party Web sites or email solicitation) or visits a Commission Junction Network site, we send a Cookie and/or gif file to assign an anonymous, unique identifier to the end user's Internet browser. One function of these Cookies is to provide Commission Junction with information for the purpose of paying third-parties commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser's Web site. If the Internet user re-visits the advertiser's site directly, Commission Junction is able to continue to track the user's activities (excluding PII) on the advertiser's site and reward the third-party Web site that referred the user. We may use Cookies to estimate the total reach of an advertising campaign, as well as frequency of display. This allows advertisers to determine with greater accuracy the composition of the audience they reach. Cookies may also be used to control the delivery of a series of advertisements to a web browser, and to limit the number of times a web browser receives any one advertisement. We also may use Internet browsing and online purchase data associated with an anonymous identifier to develop a predictive statistical user profile of the end user's needs and interests. We reserve the right to retain all ad delivery and reporting data as long as may be reasonably necessary for accounting and audit purposes.

There are two classes of Cookies based on how long they remain on an internet enabled device: (i) "Session Cookies," which are used only during a web user's visit to a website or web page and are erased once such user closes the browser, and (ii) "Persistent Cookies," which remain on a web user's browser for no more than 5 years from a user's last interaction with an advertisement.

A useful resource on understanding Cookies may be found at http://www.allaboutcookies.org.

SHARING YOUR INFORMATION

Information Shared by Commission Junction
Commission Junction will only share your Information for the limited purposes provided for in this Privacy Policy. This may include sharing Information (1) to enable third party service providers to assist or facilitate in the services we provide to our clients; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (3) to enforce our terms of use and other agreements or to protect our rights; (4) to protect the safety of members of the public and users of the service; (5) with other ValueClick Entities and third party marketing partners (including advertisers and publishers) for marketing purposes; (6) with vendors, administrative service providers, technology providers, and carefully selected partners for data validation, enhancement, information verification and suppression services; or (7) for any other purpose for which you provide consent. We may share Information with other ValueClick Entities, advertisers, publishers and other third parties for marketing purposes and online behavioral advertising, but such Information does not include PII; provided, however, such ValueClick Entities, advertisers, publishers and other third parties may combine such Information with any PII that you may choose to give in registering and transacting with their websites and other platforms, and such information and PII may be sent through Commission Junction to the relevant ValueClick Entities, advertisers, publishers and other third parties. With respect to online behavioral advertising, we, the ValueClick Entities and other third parties may use non-personally identifiable information collected or shared with respect to your visits to websites we have relationships with for various purposes, including, but not limited to providing advertisements about goods and services likely to be of greater interest to you. Typically a cookie or third party web beacon is used to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, please click on the following link: www.networkadvertising.org. While Commission Junction chooses its business partners and clients carefully and strongly encourages them to adopt responsible approaches to online marketing, Commission Junction is not responsible for the information and privacy practices of such third parties. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from this Privacy Policy. You should check the applicable privacy policies of these third parties to determine how they handle any information they receive.

In the event that Commission Junction is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your Information is treated, transferred, or used.

Information Collected by Third Party Sites
Please be aware that our website, the websites of our advertiser and publisher clients as well as the websites on which we place advertisements or any third party websites linked to one of our sites also may collect information from you for various purposes, including, but not limited to providing advertisements about goods and services likely to be of greater interest to you. Such information collected by such websites and their affiliated or third party partners may include non-personally identifiable information through the use of Cookies and other technology and any personally identifiable information you may choose to give in registering and transacting with such website. These companies typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, please click on the following link: www.networkadvertising.org. Although we choose our business partners and clients carefully, Commission Junction is not responsible for the privacy practices of such third parties. You should check the applicable privacy policies of such third parties to determine how they handle any information they collect from you.

YOUR CHOICES

You will have the option of blocking the use of Cookies by changing a setting in your Internet browser. Please see your browser supplier's Web site for details on how to do this. In order to opt-out of CJ tracking you can delete cookies stored in your browser under the emjcd.com, kdukvh.com, qksrv.net, commission-junction.com, pkracv.com, and apmebf.com domains.

DATA PROCESSING/SAFE HARBOR

FOR EUROPEAN UNION AND SWISS CITIZENS.

The European Union ("EU") maintains strict privacy laws. These rules differ significantly from the laws of the United States of America ("U.S."). To reconcile these differences, the U.S and the EU have created a safe harbor that defines mutually acceptable privacy operations ("U.S.-EU Safe Harbor Framework"). The U.S. and Switzerland have created a similar safe harbor (“U.S.-Swiss Safe Harbor Framework”). For more information see www.export.gov/safeharbor.

Commission Junction complies with the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks 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 the company's certification, please visit http://www.export.gov/safeharbor.

In compliance with the U.S.-EU and U.S.-Swiss Safe Harbor Privacy Principles, Commission Junction, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Commission Junction, Inc. at cjprivacy@cj.com.

Commission Junction, Inc. has further committed to refer unresolved privacy complaints under the U.S.-EU and U.S.-Swiss Safe Harbor Privacy 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 Commission Junction, Inc. please visit the BBB EU SAFE HARBOR website at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.


Security
Commission Junction employs appropriate measures to ensure the security of all Information, and we routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.

CHANGES

As the standards governing Internet privacy continue to evolve, Commission Junction may find it appropriate or necessary to update this Privacy Policy from time to time. As a result, we reserve the right to change this Privacy Policy at any time and shall post such changes on the Website. Our Website will state the date the Privacy Policy was last updated. We encourage you to review the Privacy Policy whenever you use this Website to make sure you understand how your information will be used.

MISCELLANEOUS

Children's Privacy
Commission Junction is very sensitive to the issue of the privacy rights of children. Commission Junction Websites and services generally are neither developed for, nor directed at, children.

Your Representations
YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose Information you supply to us with regard to: (a) the purposes for which such third party's Information has been collected; (b) the intended recipients or categories of recipients of the third party's Information; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about him/her. It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy. C'est la volonté expresse des parties que la présente convention ainsi que les documents qui s'y rattachent soient rédigés en anglais.