PRIVACY POLICY


Data protection is an important subject for NEORY GmbH. As a German company, we are committed to following the strict standards of the German data protection. These also include us willingly informing our customers and users of which data is being stored and in which way data is evaluated and processed.

WHAT DATA WE COLLECT
Cookie and pixel Information: Cookies and pixels provide us with the ability to create an ID in order for us to match collected data to an anonymous machine including:

- The URLs (or website address) of web pages which have been viewed
- The date and time of visit to a web page
- Whether the user has clicked on an ad of one of our advertisers, visited their website, or undertaken a transaction with them

Session information: This information relates to user, campaign and interest-based history and is used for frequency capping and interest targeting. This information is gathered from visited websites and registered clicks by the user's machine.

Request-based information: This information is passed to us by the user's computer browser with every request and is stored entirely anonymously for statistical purposes only:

- IP (Internet Protocol) addresses - Every device connected to the Internet has an IP address. This cannot be traced to an individual user but can be used for geographic targeting and statistical measurements
- Browser type - e.g. Are you using Google Chrome, Microsoft Internet Explorer, Firefox or Safari
- Computer Operating System - e.g. Are you using Windows 8, Apple OS or Linux

We may purchase anonymous data from third-party sources. This data is anonymous and is used to update existing user profiles. We do not share, rent or sell any of the data acquired from third party sources.

PERSONALLY IDENTIFIABLE INFORMATION

We do not collect any personally identifiable information. The IAB (Internet Advertising Bureau), which is a trade association for the internet marketing industry, defines personally identifiable information as 'information that can be traced back to a specific user and provide personal information such as name, address, phone number, etc.' In other words, it's information about you that can identify you as a person rather than an anonymous profile. All of our profiles are anonymous, and relate to a computer or client (your browser) rather than a user. For us, they are nothing more than a number with which we associate interests and/or an estimated or inferred demographic profile.

COOKIES AND PIXELS
Cookies are small text files that are stored within a folder on your computer and are used only by your internet browser. They are not programs or applications, they are merely a marker of our previous contact with you. They take up a tiny amount of space on your computer and can be used to uniquely, but anonymously, identify your computer or client (your browser). Most websites use cookies to identify users and improve the user experience. The NEORY cookie does not harm your computer in any way or provide us with any information about your identity. Our cookie is not spyware or adware. The general definition of spyware/adware is that of a software package installed on your computer for purposes of monitoring all your internet or general computer activity. We do not install software of any kind on your computer and have no ability to monitor or track your general computer or overall internet usage. Cookies can be easily avoided by opting out from them, or adjusting your browser settings. Tags are small text files (javascript) used to track website visitation and actions taken by users on these websites. The information collected from the tags is stored in the cookie.

HOW WE USE THIS DATA
NEORY uses the collected information to target advertising campaigns more effectively. The aim is for you to see ads which you are more likely to be interested in, rather than ads that you aren't. We do this by comparing the information relating to the machine's anonymous profile, against our selection of ad campaigns and choosing the most suitable advertisement. It's important to understand that NEORY can only create these profiles and display ads to you when you visit a website that we have a relationship with. Most websites you visit will not charge you, but are funded by the ads that you view. The more effective the advertising on a site, the more money it can generate from fewer ads – reducing the clutter and invasiveness of the advertising on their websites. Identifying anonymous profiles allows NEORY to offer an improved online experience for you, increased performance to our advertisers and enhanced revenues for our website-partners. We do not sell, rent or share any of the anonymous data to third-parties.

DATA RETENTION
NEORY maintains all server log data (see ‘What data we collect') and data stored in the cookie for a period of 90 days to comply with audits, court order or law enforcement inquiries. After 90 days all of the stored data is destroyed. Summarized data is kept indefinitely. Summarized data is aggregated statistical data (impressions and clicks) used for financial reporting purposes.

ACTION ATTRIBUTION
To gain a greater understanding of a site's performance, or a user's general interests, we use a variety of technologies to determine which websites in our network the user visited previously and/or where the user clicked on an advertisement. Using this information, we can calculate which websites and/or which broad interest characteristic of a user is likely to best respond to a particular campaign.

This takes two forms:

- Performance attribution: We monitor the sales, signups or visits to certain predetermined pages on our advertiser's websites. We reconcile these page 'hits' back to the ads that were shown to allow us to manage advertising campaign delivery, and report on this to our advertisers and publishers (e.g. website partners or 3rd party ad networks). We use cookies to limit the number of ads any individual computer or client is exposed to.
- User interest profiling: To create a user interest profile, we observe which websites within our network users have interacted, and we determine what topics those websites are about. This information is combined to generate an anonymous interest profile for specific computers or clients. Depending on the content of the websites users visit, we build an anonymous profile which contains information on potential interests and a statistical estimate of their likely demographic. For example, if a user visits a sports site within our network then we may classify them as broadly interested in that sport. All data that we use is stored anonymously.

OPTING OUT
If you prefer not to have online advertising tailored to a user interest profile, you may opt out at any time.
- Opt out of NEORY's user interest targeting cookie by clicking the link above. Please note that if you delete your cookies, change browsers, or use a different computer, you will need to opt out again.
- Disable cookies in your browser (typically under Tools/Options/Privacy, but this varies between browser types and versions). Please note that cookies are used for a variety of reasons, not just targeting advertising, so this may adversely impact your online experience.
It should also be noted that opting out does not mean you will not see advertisements online, but these advertisements will not be targeted based on your online user interest profile from us.

Online Behavioral Advertising / OBA
NEORY GmbH adheres to the European Digital Advertising Alliance (EDAA) Self-Regulatory Principles for Online Behavioral Advertising in the EU. Please find additional informations about the principles on this site:
http://www.edaa.eu/


NEORY GmbH adheres additionally to the Self-Regulatory Principles of the German Data Privacy Council ("Deutscher Datenschutzrat Online-Werbung (DDOW)"). The actual Self-Regulatory Principles can be seen here:
http://meine-cookies.org/DDOW/die_kodizies/index.html

Besides the options below to opt-out for specific online behavioural advertising, you can find the possibility to opt-out from online behavioural advertising from us and other market participants on the following site:
Germany: http://www.youronlinechoices.com/de/praferenzmanagement/
United Kingdom: http://www.youronlinechoices.com/uk/your-ad-choices/

Please find further informations from the European Interactive Digital Advertising Alliance about Online Behavioural Advertising on this site:
http://www.youronlinechoices.com/

SECURITY
If you provide us with your contact or business information in order to conduct business with us as an advertiser or publisher, NEORY uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to NEORY and you do so at your own risk. NEORY takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store data.

CORRESPONDENCE
If you contact us, we may keep a record of that correspondence and we may collect your name and email address. This relates to this correspondence only – and is not part of our core online business.

CHILDREN'S PRIVACY
NEORY is very sensitive to the importance of children's privacy and employs a zero-tolerance approach to advertising to children. NEORY's websites, products, and services are neither developed for, nor directed at, children. NEORY does not employ or offer targeting towards children under the age of 18. If you believe your child has provided NEORY with personal information, or registered at one of NEORY's websites, and you would like to have the data removed, please contact us.

CHANGES TO PRIVACY POLICY
This privacy policy is subject to change without notice. If you visit our website or use our services, the terms and conditions of this privacy policy as displayed at that time apply.

EFFECTIVE DATE
The privacy policy was last revised on November 23rd, 2016.

QUESTIONS AND COMMENTS
NEORY GmbH
Hafenpromenade 3a
D-44263 Dortmund
privacy@neory.com