ALC Privacy PoliCy

ALC PRIVACY POLICY

Who we are

Last updated: November 2019

This privacy policy (“Policy”) applies to information collected through ALC, LLC (“ALC,” “we,” “our,” or “us”) www.alc.com (the “Site”).

Introduction

Welcome to the ALC Privacy Policy.  By visiting our Privacy Policy, you’ve taken the first step in educating yourself about advertising businesses, which contribute to the economy’s ability to remain a place where large and small companies can sell products and services affordably through relevant marketing.  Additionally, ALC helps the internet continue to be an ecosystem consisting of free content funded by advertising. 

ALC provides online (e.g., banner advertising) and terrestrial (e.g., traditional direct mail) marketing services.  To do this, we follow a privacy methodology that balances the consumer privacy efforts with the need to encourage and support a growing and diverse internet with the utilization of data.  This belief structure supports a personalized marketing experience that brings benefits to the consumers through more advance marketing strategies through better personalization and more free publisher content on the internet when done properly.

When you use or visit our Site, we collect the following types of information:

  • Personal information you choose to provide to us, for example, when you make requests for information and assistance, such as:
    • Your name;
    • Mailing address;
    • E-mail address; and
    • Telephone number.
  • Information about the company for which you work.
  • Sensitive information, to register for certain products and services. 
  • Technical information, through our use of cookies, sensors, log files, and other technical mechanisms, such as:
    • Browser type;
    • IP address;
    • Mobile device type and identifier;
    • Screen resolution;
    • Operating system;
    • The date and time of a visit or use;
    • The pages visited on the Site; and
    • The time spent viewing particular pages of the Site.

To view the Terms of Service for using this Site, please visit https://alc.com/terms

By visiting any ALC website and sharing any information with us, you agree to be bound by this Privacy Policy and the Site’s Terms of Service.

To begin, it is important for you to know two definitions that are key to understanding our services and privacy practices:

Personally Identifiable Information (“PII”): Information that can be linked to a individual person.  This type of data includes things like full name, home address, telephone number, or email address.

Non-Personally Identifiable Information (“Non-PII”): Information that cannot identify an individual person, such as an IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.

CONTENTS OF THE PRIVACY POLICY

  1. Short Form Privacy Policy
  2. Scope
  3. What ALC Does
  4. Privacy by Design
  5. Information Collection & Use
  6. ALC Does Not Intend to Market to Children
  7. Information Security
  8. Self-Regulation and Voluntary Compliance
  9. Your Choices
  10. Changes to our Privacy Policy
  11. Privacy Officer Contact Information
  12. Your Representations

SHORT FORM PRIVACY POLICY

We have included a table summarizing our practices solely for your convenience and reference purposes. This table 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 this Privacy Policy. As a result, we encourage you to review the entire Privacy Policy:

Information Collection:
PII
We collect PII on behalf of our clients to manage and monetize their data within compliance of the law and voluntary self-regulation. For example, PII may be collected should a marketer wish to send a direct mailer or catalog.  Additionally, a consumer may wish to provide PII on his/her own initiative, register with a publisher to download a mobile app, or want to add their information for lead generation purposes with ALC or its client.
Information Collection: Non-PII The Non-PII we collect may include, as an example, IP address, browser types, operating systems, domain names, platform type, language preference, access dates and times, referring website addresses, online transactions web browsing, and search activity.
How Information is Used We may use your PII to mail you an offer to your home address or Non-PII for purposes such as enhancement of our digital services for online marketing, and to more effectively match advertisements, applications, and website content to your interests.
Sharing Your Information We may share your information with third party service providers with whom we have contracted, our subsidiaries and affiliates, third party marketing partners, business partners and our clients and publishers, as expressly provided for.
Your Choices You may regulate the collection and use of Non-PII via the opt-out options provided herein or by uninstalling or electing not to install a web browser or mobile application.
Security We use reasonable and appropriate security measures to protect your data.
Retention We retain online Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data.  We serve as an agent for our clients to manage their first party data and will retain that data based on each of their specific retention policies.
Changes We may change this Privacy Policy at any time by posting the revised Privacy Policy on the Site along with the date such Privacy Policy was last updated.
Contact Us If you have any questions about this Privacy Policy, or the practices discussed herein, please contact us at privacy.officer@alc.com.

SCOPE

This Privacy Policy is primarily intended to provide a description of the ways in which we collect and use information to deliver advertising through direct mail and digitally across the Internet. This Site is not intended for use by those who are not legal residents of the United States. Neither the Sites, nor our online activities or services for our clients, are directed toward or intended for children. We do not collect PII from any person of whom we have actual knowledge is under the age of 18. By using our website, the website of any of our publishers in our networks or submitting information to us, you consent to our use and sharing of the information collected or submitted as described in this Privacy Policy.

Please be aware that in addition to our Sites, the websites of our clients and publishers, applications on which we place advertisements and any third party websites linked to one of our Sites, may also 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 mobile applications and their affiliated or third party partners may include Non-PII through the use of cookies and other technologies. It may also include any PII you choose to provide in registering and transacting with such websites and mobile applications. Although we choose our business partners and clients carefully, ALC is not responsible for the privacy practices of websites and mobile applications operated by such third parties. You should check the applicable privacy policies of such websites and mobile applications you visit to determine how they handle any information they collect from you.

WHAT ALC DOES

ALC operates a data management business for its clients for terrestrial (e.g., direct mail) and digital advertising technology (the “Technology”) enabling marketers to target advertising based upon our proprietary composite of multiple intent signals of users and to recognize devices that you may use to connect to the Internet such as computers, mobile devices, tablets, smart TVs, game consoles and any other device that enables data collection and exchange (all referred to as “Screens”) for the purpose of sequential targeting, interest-based advertising, cross-screen attribution, and optimization of digital advertising. We help advertisers, advertising networks, online merchants and websites (our “Clients”) do a better job at engaging with their customers and prospects (their “Users”). This Privacy Policy covers the data collected by ALC’s Technology as well as the information collected on www.alc.com (the “Website”).  ALC is a member of a number of industry associations that govern the policies around online consumer privacy and digital advertising, including the Digital Advertising Alliance (DAA). We comply with Self-Regulatory Principles for Online Behavioral Advertising (OBA) and Internet Advertising Bureau (IAB).

PRIVACY BY DESIGN

Our philosophy on privacy follows the framework of Privacy by Design. We integrate privacy in strategy, product development, and more. We can protect consumer privacy AND provide relevant advertising, which benefits everyone involved, especially advertisers, consumers, and small business websites and mobile applications. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance, and we are careful to protect privacy as data is collected, used, and destroyed responsibly.

We constantly strive to maintain unparalleled visibility with consumers. We provide transparency and choice through our website, encourage the same practice throughout the Internet, and utilize AdChoices on each banner advertisement and through AppChoices for providing choice and tailoring ads to consumers’ interests.  We respect consumer privacy and give consumers the ability to opt out of interest-based advertising (“IBA”).

INFORMATION COLLECTION AND USE

We collect information from your use of our Technology. When you visit any website, mobile site, app or other digital media property where our Technology is enabled (“Client Sites”), we may collect information about your interaction with, and the content on, that Client Site. The information collected via the Technology is put into a “snapshot” and is sent to our servers each time a User visits a Client Site. Our servers use the information to create a unique ID for every Screen that our technology is able to recognize within a reasonable probability. Our Technology uses machine learning to perceive common characteristics between multiple Screens (e.g., common IP address) to infer the likelihood that two Screens belong to the same household. By inferring these types of relationships, we can help our Clients understand how Screens might be related so Clients can deliver advertising and content personalized to their Users based on User interests gathered across multiple Screens. ALC may use non-PII that it has collected or that it obtains from third parties to create data segments and intent profiles, based upon User interactions with our Clients as well as other User behavior, such as the websites visited and mobile applications used by a User.

ALC licenses the data collected as described herein to third parties in connection with our business, including to our Clients, our partners and other third parties (collectively our “Business Partners”). This shared information may include non-PII information about your particular Screen (e.g., hardware make and model), its operating system, advertising identifiers (such as Apple IDFA or AAID), IP address, carrier identifiers and other connectivity information, browser version, precise geolocation information, and cookies. This information may be categorized to create audience segments with common interests, intent or other characteristics, but does not include PII. We may also share aggregated, non-PII with our Business Partners, such as aggregated reports derived in part from the information we have collected. The information we share may also be combined with third party data to provide an even broader service to our Clients and Business Partners.

ALC supports the NAI Code of Conduct’s obligations around the collection and use of health information for interest-based advertising.  This health-related information, when collected and/or used for relevant advertising, is non-sensitive and consumers may exercise choice through an opt-out basis.  The NAI also permits ALC to collect and use sensitive health information when the user provides explicit opt-in consent in the United States.  For a list of health segments used by ALC, click here.

We may disclose information collected from the Website and through the Technology we have if we have a good-faith belief that the disclosure is reasonably necessary to comply with the law, legal process or an enforceable government request; to enforce applicable terms of use for our services; to detect, prevent or otherwise address illegal activity, fraud, or security issues; or to protect the property or safety of our users, ALC, or the public as required or permitted by law. We may also make both PII and non-PII available to subsidiaries and affiliated companies that are under common ownership or control within the ALC family.

We may transfer information, including PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If ALC is involved in any such transaction, you will be notified via prominent notice on our Website of any change in ownership or uses of your information, as well as any choices you may have regarding your information.

We also provide information to third parties who provide services to ALC in connection with operating and maintaining the Website and the Technology. These service providers are prohibited from using the information we provide for purposes other than performing services for ALC. In addition, we may share aggregated information with Business Partners and the general public, such as usage statistics or demographic trends regarding how you and others may interact with the Website and/or Technology.

INFORMATION SECURITY

The security of your information is important to us. ALC has implemented reasonable security measures to protect the information, both during transmission and once it is received, including without limitation, use of firewalls, application controls and encryption. No method of electronic storage or transmission over the Internet is 100% secure. So while ALC strives to use commercially reasonable means to protect your information, we cannot guarantee complete security. If you have any questions about these security practices, please email us at privacy.officer@alc.com.

ALC DOES NOT INTEND TO MARKET TO CHILDREN

ALC’s Website and Technology is designed for people 18 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 the age of 13, we will use reasonable efforts to remove that information from our records.

SELF-REGULATION & VOLUNTARY COMPLIANCE

Our industry has a rigorous voluntary self-regulatory regime, and we are active members of industry groups such as the Network Advertising Initiative (NAI), Interactive Advertising Bureau (IAB), Digital Advertising Alliance (DAA) and Digital Advertising Alliance of Canada (DAAC) who promulgate codes of conduct to which their members must adhere. These codes impose requirements on participating companies such as transparency and choice around the use of data for IBA and require regular audits of member privacy practices.

ALC is an active member of these and other groups, and where ALC engages in activities regulated by these programs, we comply with the NAI Codes of Conduct. We also support the DAA Self-Regulatory Principles and the DAAC Self-Regulatory Principles

YOUR CHOICES

ALC wants you to be in control of your experience while interacting with the Website and our Technology. We help our Clients provide you with digital advertising that’s meaningful and supports the Client Sites you use for free, so everyone wins. For more information about online behavioral advertising, please visit the DAA website.

ALC Intent Data Collection Web Browser opt-out: If you’d like to opt-out from web-based targeted advertising from ALC, please click here. If you’d like to opt-out from Appnexus, click here. If you’d like to opt-out from online behavioral advertising from any DAA member company, please click here. When you opt-out, our partners such as Appnexus will drop an opt-out cookie that tells our Technology not to deliver targeted advertising to that particular browser or device. If you delete, block, or otherwise restrict cookies, or if you use a different browser or device, you will need to renew your opt-out choice. Please note that you will still see ads if you opt out. The ads delivered through the Technology will just be less relevant to you. We provide you with meaningful choices regarding opt-outs for data collection, including the opt-out links above. However, we do not recognize or respond to browser-initiated Do Not Track (DNT) signals, and we do not control how our Clients respond to DNT.

ALC Intent Data Collection Mobile Device opt-out: We also honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). For devices where we are able to see that such a selection has been made, we will not use information collected from that device to deliver targeted advertising.

ALC Cross-Device opt-out: If you’d like to opt-out of cross-device tracking from ALC we will not share the identity of your device with our Clients for the purpose of enabling online behavioral advertising. Note that we do have some Clients who use our Technology on their own Client Sites, including for things like fraud prevention, which are not subject to opt-out choice. To opt-out of tracking click here.

We may also work with third parties that collect data about your use of the Site and other websites or apps over time for non-advertising purposes.  Among these third parties, we may use Google to improve the performance of the Site and for analytics and marketing purposes.  For more information about how Google Analytics collects and uses data when you use our Site, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

Unsubscribe or Opt Out from Promotional Communications

ALC offers you the opportunity to opt out of receiving promotional e-mail, calls or mail from ALC about our products and services.  To do so, contact ALC using the contact information listed below.

For e-mail, individuals may opt out at any time by using the unsubscribe mechanism within the e-mail, which allows individuals to manage their subscription preferences regarding ALC newsletters, e-mail alerts and special offers. This mechanism does not allow a user to opt out of receiving transactional e-mail, such as registration confirmation, product updates and responses to direct requests. 

Privacy Offer Contact Information

ALC, LLC

750 College Road East, Suite 201, Princeton, NJ 08540

Email: privacy.officer@alc.com

California Privacy Rights

As described in this Policy, we may make personal information available to third parties for their marketing purposes.  California residents may opt-out of ALC’s disclosure of personal information to third parties for their direct marketing purposes pursuant to California Civil Code section 1798.83 by emailing privacy.officer@alc.com.

Changes to our Privacy Policy

We may modify this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will post the modified Privacy Policy to the Website with an updated “Last Updated” date at the top of the Privacy Policy, and other places we deem appropriate. We reserve the right to modify this Privacy Policy at any time. If you have questions or concerns, you may contact us at: privacy.officer@alc.com.

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 them. 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.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.