This Privacy Policy was last updated on April 3, 2012

TellApart Inc. (“TellApart”) provides e-commerce sites and advertisers (“Business Partners”) access to a set of technologies and processes designed to display advertisements to consumers viewing a publisher’s website(s) (the “TellApart Ads”).

This Privacy Policy describes TellApart’s privacy practices as they pertain to (i) visitors to our website located at www.TellApart.com (our “Site”), and (ii) our targeted advertising technology service (“Technology”).

If you have any questions about this Privacy Policy, please feel free to contact us at info@TellApart.com.

1. Site — Information Collection and Use

The Site is intended primarily to offer information about TellApart and the services we provide.

Information Collected via the Site

We collect Personally Identifiable Information (“PII”) from the Site when you choose to provide it to us. PII is any information that can be used to identify a particular person or entity. This includes, but is not limited to: name, postal address, telephone number, or email address. For example, you may choose to send us PII about yourself in an email or by completing an online form on this Site. We use this information only to contact you to respond to your inquiry. We also collect Non-Personally Identifiable Information (Non-PII) via the Site. Non-PII cannot be used to identify any single person or entity and may include your IP address, pages viewed on this Site, browser type, Internet Service Provider, the time/date of your visit to this Site, and your computer’s operating system (e.g., Windows XP).

Cookies and Web Beacons

We use “cookies” and web beacons to help us manage this Site. Cookies are small text files that contain a string of alphanumeric characters. We also use persistent cookies on this Site in order to help us manage the opt-out process for our Technology. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Web beacons (also known as “1X1 pixels” or “clear GIFs”) are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For more information about cookies and web beacons please visit http://www.allaboutcookies.org/cookies/.

Third Party Websites

The Site may contain links to other websites. Such websites may use cookies and/or other data collection tools. TellApart is not responsible for the privacy practices, policies or content of such other websites. TellApart encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. TellApart has no control over the use of information by third party websites, and you should exercise caution when deciding to disclose any PII to those websites.

2. TellApart Technology — Information Collection and Use

Overview of TellApart’s Technology and Data Collection

Our Technology collects information about the website(s) that you visit and the advertisements that you see while online. We may collect data about you using our Technology in the following contexts: when TellApart or one of our Business Partners purchase online advertisements on a website that you visit (“Advertising Data”); and/or when one of our Business Partners uses our Technology on its website, which you visit (“Business Partner Data”). The type of Advertising Data we collect includes the number of advertisement requests received, the number of advertisements you are shown, the identity of the website you are visiting and the number of clicks you may make on a particular advertisement, but in all cases Advertising Data is Non-PII. The type of Business Partner Data we collect includes information regarding the pages and products you have viewed, the identity of products purchased, the time you spend on particular web pages and product price. Business Partner Data may in some cases include PII. However, we do not associate this information with the information that is separately gathered off the Business Partners’ websites through our online advertising activities.

We use the information collected by our Technology in order to help make the TellApart Ads you see more relevant to you, to improve our Technology, and for ad delivery purposes. We also may disclose Non-PII to our Business Partners in connection with the provision of TellApart Technology services.

Cookies, JavaScript and Web Beacons

TellApart uses cookies, JavaScript and web beacons in connection with our Technology and our collection of both Advertising Data and Business Partner Data. These types of technologies help TellApart better understand the effectiveness of a TellApart Ad (for example, by tracking the way in which you may respond to, select and interact with a TellApart Ad or any content provided therein, or the location and context in which you view a TellApart Ad). TellApart’s cookies also help control the number of times you view a TellApart Ad. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to enjoy the full functionality of many of the websites you visit.

TellApart also uses JavaScript and web beacons, in combination with cookies, to analyze usage patterns. The use of these technologies allows TellApart to record that someone has visited a particular webpage, along with additional Non-PII that the website may choose to include with the beacon.

Information Received from Other Third Parties

In some cases, we may choose to work with third party data providers to support requirements that may arise from our Business Partners. For example, our business partners may use our technology to combine anonymous third party data with the data collected by our technology in order to further tailor advertising content to their customers. In conjunction with information collected using our Technology, we use this information in order to help make the TellApart Ads you see more relevant to you, to improve our Technology, and for ad delivery and reporting purposes.

Third Party Links and Websites

TellApart Ads may contain links to other websites, including those of our Business Partners. Such websites may use cookies and/or other data collection tools. TellApart is not responsible for the privacy practices, policies or the content of such websites. TellApart encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. TellApart has no control over the use of any information by third party websites, and you should exercise caution when deciding to disclose any PII. Similarly, TellApart does not have access to, or control of, the cookies and/or other data collection tools that may be placed on any advertisement by a third-party, including those of our Business Partners, and this Privacy Policy does not cover the use of cookies and/or other data collection tools by any third party.

3. Our Disclosure of Your PII

TellApart is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your PII with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, PII may be part of the transferred assets. You acknowledge and agree that any such transferee will have the right to use your PII as disclosed herein.

Agents, Consultants and Related Third Parties: TellApart, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include maintaining databases, hosting services and the like. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: TellApart may disclose your PII if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of TellApart or others, (iii) act in urgent circumstances to protect the personal safety of our users or the public, or (iv) protect against legal liability.

4. Information Security

The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to the use of encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its security.

If you have any questions about our security practices, please send an email to us at info@TellApart.com.

5. Opt-out of Information Collection

If you would like to opt-out from having TellApart collect information about you in connection with our Technology, please click here to opt-out. When you opt-out, we will place an opt-out cookie on your computer. This opt-out cookie tells us not to collect information about you to tailor TellApart Ads to your interests, and we will no longer do so as long as this cookie is present on your computer and you are using the same Internet browser.  Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer or Internet browser, you will need to renew your opt-out choice.  To opt-out of the behavioral advertising delivered by additional NAI (Network Advertising Initiative) member companies please click here.

6. General Information

When working with sites whose product catalog includes personal care items, we do not have access to your medical information or collect sensitive information regarding your health or medical conditions but may on occasion display advertisements for non-sensitive products such as soap, clothing and toys for infants.

Data Retention

Non-PII data related to online behavioral advertising is stored with the TellApart cookie and is deleted when the cookie expires, which is currently set to two years from the last time you have visited a TellApart business partner.

Information Relating to Children

Our products and services are designed for those 13 years of age and older. We do not knowingly collect PII from anyone under the age of 13. If we are made aware that we have received PII from someone under 13, we will use reasonable efforts to remove that information from our records.

Updating your PII

If you would like us to update, correct or delete any PII about you that we may possess, please send your request to us questions or concerns relating to privacy, please send us an email at info@TellApart.com and we will process your request within a reasonable period of time after receipt.

Changes to this Privacy Policy

This privacy policy is subject to change. If we make any material or substantive changes in the way that we use the PII collected through this Website, we will post notice of those changes on the Website and in this privacy policy.

Contact Information

For questions or concerns relating to privacy, please send us an email at info@TellApart.com. Alternatively, you may contact us at: TellApart Inc., 257 Myrtle Road, Burlingame, CA 94010