Last Updated: July 8, 2014
BlueKai's mission is to build the world's most comprehensive online data directory with utmost attention and diligence to help ensure your anonymity and privacy. Our business is based upon the collection and use of anonymous customer preferences via partner websites in order to allow advertisers, publishers, and other content providers to deliver content that is relevant and meaningful to their users. Because we want to put you, the consumer, in the driver's seat, you can enhance your preferences in our directory by selecting or de-selecting topics of interest. Your preferences may be used anonymously to influence which types of marketing messages and other content are displayed to you across partner sites that we work with. We also allow you to choose not to participate in our directory at all. We are a member of the Network Advertising Initiative (NAI) and work with industry-leading companies to address important privacy and consumer protection issues in online advertising. Click here to learn more about the NAI. We also participate in the Digital Advertising Alliance (DAA) and European Digital Advertising Alliance (eDAA) self-regulatory programs and adhere to the DAA and eDAA Principles for Online Behavioral Advertising. Click here to learn more about the DAA. Click here to learn more about the eDAA.
BlueKai complies 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 personally identifiable information from European Union member countries and Switzerland. BlueKai has certified that it adheres 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 page, please visit http://www.export.gov/safeharbor/
Overview of Our Services
We collect non-personally identifiable information regarding offline collected attributes and digital usage patterns of users of mobile devices and computers. In this policy, we refer to this non-personally identifiable information, together with other non-personally identifiable information that we obtain from third parties in order to influence which types of marketing messages and other content are displayed to you, as "Preference Data." We use Preference Data to prepare groups of users, referred to as "segments," based upon their behavior and preferences. We give our customers a limited right to use a user's membership in a segment as a basis for displaying advertisements and other content that are intended to reflect the user's preferences. We also collect non-personally identifiable information for other purposes: for example, to provide aggregate statistics for market research and analytics programs.
Collection of Preference Data
We use non-personally identifiable means, including "cookies", "pixel tags," and in some instances, statistical ID's, to collect and store Preference Data. We do not use flash cookies.
Cookies are small text files that contain a string of characters and uniquely identify a browser. They are sent to a computer by Web site operators or third parties. Most browsers are initially set up to accept cookies. You may, however, be able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. Check your browser's "Help" files to learn more about handling cookies on your browser. BlueKai cookies will expire after six months from the date they are created.
Pixel tags are small strings of code that provide a method for delivering a graphic image on a Web page or other document. Pixel tags allow the operator of the Web page or other document, or a third party who serves the pixel tag, to set, read, and modify cookies on, and to transfer other data to, the browser used to view the Web page or other document. Pixel tags may also be used to obtain information about the computer being used to view that Web page or other document. The entity that sends the tag can view the IP address of the computer that the tag is sent to, the time it was sent, the user's operating system and browser type, and similar information.
We use information collected at various times and by pixel tags and cookies placed on several Web sites in order to collect Preference Data. We may also obtain Preference Data from third-party sources, and may combine it with other Preference Data that we have collected.
The Preference Data that we collect from users includes, for example, a user's browser type and version (e.g., Internet Explorer 7.0, Firefox 3.0, or Safari 3.1.1), and operating system (e.g., Windows Vista, Macintosh OS X, or Android 4.1 for certain mobile users). We also may collect demographic information such as a user’s gender, age, and income range. In addition, we may collect information about a user's browsing behavior, such as the date and time they visit the Web pages on which we are collecting Preference Data, the content areas or pages of the Web sites that a user visits (e.g., "sports section" or "technology section"), and other click-stream data, none of which includes personal information about the user.
Preference Data is deleted after six months of original date of collection.
Your Access to and our use of Preference Data
We analyze Preference Data collected from various sources and at different times to define segments and to attribute membership within those segments to users. Our policy is to purge Preference Data within six months from the data it is collected.
We are aware of the sensitivity of certain types of Preference Data. We do not create or share any segments on the Audience Data Marketplace that reflect Preference Data that we consider sensitive. While the types of Preference Data that may be considered sensitive may vary among users, we presently treat Preference Data as sensitive if it includes data reflecting a user having a medical condition; certain aspects of a user's personal life or financial situation; or use of, or interest in, gambling, alcoholic beverages, or "adult" products or services. If you'd like to view the list of health and wellness Preference Data segments available on the Audience Data Marketplace, please click here. If you’d like to view and edit all the Preference Data that are applicable to this computer, please visit the BlueKai Registry by clicking here. We may update from time to time the types of Preference Data that we consider sensitive.
Disclosure of Information
We disclose Preference Data, and information derived from Preference Data, to our customers (including the Yahoo! Ad Network) in the ordinary course of our business. We indicate to our customers a user's membership within a segment at various times. For example, we may tag an anonymous user as a member of a segment when the user views certain Web pages that are operated or controlled by a customer. Our customers may use a user's membership within a segment to display advertisements and other content that are targeted to the user. Our customers may also use third-party service providers, acting on behalf of those customers, to display advertising or other content that reflects a user's membership in a segment. We do not authorize our customers to resell Preference Data to third parties. Please note that our customers have their own data retention policies.
We may share Preference Data with third-party service providers (e.g., data storage and processing facilities) in order for those service providers to perform business functions for us or on our behalf.
We may also disclose Preference Data if we believe that we have a legal obligation to do so.
In addition, information in our possession or control, including Preference Data, may be disclosed in connection with any merger, acquisition, debt financing, sale of company assets, or other business transaction in which data could be transferred to third parties as one of our business assets.
Mobile Device Preference Data
BlueKai enables clients to utilize Preference Data via mobile devices such as smart phones and tablets. In many respects, the process we use in mobile is similar to those we’ve used for our online Preference Data. However, as cookies are less reliable on mobile devices, BlueKai uses statistical ID’s to help us process mobile Preference Data. The use of statistical ID’s does not impact BlueKai current data retention rate.
BlueKai has also developed the Mobile Privacy Guard - a privacy enhancing technology for the mobile advertising marketplace. Mobile Privacy Guard utilizes similar noise injection techniques to those which are commonly used in various fields to protect anonymity. The BlueKai Mobile Privacy Guard inserts additional noise into the mobile Preference Data we collect, which makes it significantly more difficult for anyone – including BlueKai – to re-identify any particular mobile User. For example, when a device is “tagged” with actual behaviors performed by a device, a set of recommended attributes are injected into the mobile device profile. This ensures the mobile device is immediately anonymized to protect the consumer, but still valuable and relevant for advertisers. For more information about Mobile Privacy Guard, please contact BlueKai’s privacy department at the information provided below.
Opting Out of the Services (Our Choice Mechanism)
We provide multiple ways for you to opt out of our services.
We make available a Blue Kai "opt-out" cookie that you may download to your browser. This cookie, when installed on your browser, will prevent us from collecting Preference Data on that browser. You can learn more about our opt-out cookie here. By opting out of the BlueKai cookie you are also opting out of targeting options from BlueKai through some of our third party partners.
You may also opt out of our collection of Preference Data using tools provided by industry groups such as the Network Advertising Initiative (the “NAI”), the Digital Advertising Alliance (the “DAA”) and the European Digital Advertising Alliance (the “eDAA”). You may access the NAI opt-out tool here. You may access the DAA opt-out tool here. You may access the eDAA opt-out tool here. These opt-out tools allow you to opt out of our collection of Preference Data, as well as the data collection and preference-based ad programs of other NAI and DAA member companies.
These opt-out tools are cookie-based. Please note that these tools only prevent us from collecting Preference Data pertaining to you on the browser on which they are installed, will only function if your browser is set to accept third-party cookies, and may not be as reliable where (e.g., certain mobile devices and operating systems) cookies are sometimes automatically disabled or removed. If you delete an opt-out cookie from a browser's cookie files, we will collect Preference Data from that browser until an opt-out cookie is reset on that browser.
Additionally, you may prevent us from collecting Preference Data on a browser by blocking third-party cookies in that browser. If you block third-party cookies from being set on your browser, you may not be able to enjoy some features or functionality of, and you may see the same content and advertisements repeatedly on, some Web sites. If the BlueKai opt-out cookie is left undeleted, its opt-out function will live for up to 20 years.
Our Corporate Web site
Our Data Management Platform
We may provide reports to our customers who access Preference Data. Our customers may use these reports to determine information about available segments (e.g., the number of users in segments). These reports may also be used for billing, auditing, and other operational purposes. These reports are prepared using aggregated reports on users' activity on Web sites on which Preference Data is collected and used. To prepare our reports, we maintain log files for no longer than six months. Our reports and log files do not include any personally identifiable information about users.
We do not intentionally collect Preference Data from, and do not tailor any segments to, children under 13 years of age.
Data Security and Data Integrity
We use security measures that are designed to protect Preference Data in our control from unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any Preference Data or other information. In particular, we cannot guarantee that Preference Data or other information will not be disclosed, altered, or accessed in accidental circumstances or by unauthorized acts of others.
BlueKai processes information in a way that is consistent with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps designed to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
We retain Preference Data and other information for up to six months. After six months, some of the information we have (e.g., anonymous web logs) may be aggregated for statistical purposes and stored indefinitely, and the rest of the information is destroyed.
Updates to This Policy
We may update this policy from time to time. When we do, we will also revise the "last updated" date at the beginning of the policy. If we make a change to this policy that would result in a materially more permissive use of Preference Data that we collected before the effective date of the update, we will obtain prior affirmative consent from affected users before implementing the change.
We encourage you to review this policy periodically to stay informed about how we collect, use, and disclose Preference Data.
Enforcement, Questions and Complaints
To address any issues regarding our compliance with the NAI Self-Regulatory Principles, BlueKai, along with the NAI and other NAI members have created a compliance program that incorporates attestation reviews, a consumer complaint process, sanctions and annual reporting to help ensure that member companies keep their promises to you and abide by the NAI's Self-Regulatory Code of Conduct. Please refer to the NAI site for more information.
Safe Harbor Enforcement and Dispute Resolution
If you have any complaints regarding our compliance with the Safe Harbor program, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the Safe Harbor Principles.
If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet, fax to 415-520-3420, or mail to TRUSTe Safe Harbor Compliance Dept., (click for mailing address). If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, visit the TRUSTe feedback page or request this information from TRUSTe by fax or mail as indicated above.
Oracle has appointed a Chief Privacy Officer. If you believe your Personal Information has been used in a way that is not consistent with this policy or your specified preferences, or if you have further questions related to this policy, please contact the Chief Privacy Officer by filling out an inquiry form. Written inquiries may be addressed to Chief Privacy Officer, Oracle Corporation, 10 Van de Graaff Drive, Burlington, Massachusetts 01803, United States of America.
Oracle’s corporate headquarters are located at:
500 Oracle Parkway
Redwood Shores, CA