Last Updated: May 27, 2020
Email firstname.lastname@example.org to Opt-Out of Data Collection.
TYPES OF INFORMATION WE COLLECT
Non-Personally Identifiable Information.
“Non-Personally Identifiable Information” is information that relates to you but does not identify you individually and is not directly linked to your personal information. Examples of Non-Personally Identifiable Information include clickstream data and web-browsing information (such as the date and time you visit a website or mobile app, whether you click on various advertisements or links and the search terms you enter when using a website or app), and information about your computer, device and internet connection (such as your device type, browser type, IP address, mobile device identifier, information about mobile applications, and the geographic location of a device). Non-Personally Identifiable Information may also include Personally-Identifiable Information that has been de-identified or “scrubbed” in order to render it anonymous.
Personally Identifiable Information.
Personally-Identifiable Information” means information that on its own or in combination with other information may be used to identify, contact, or locate a specific individual. Examples of Personally-Identifiable Information include names, addresses, e-mail addresses, usernames and passwords, credit or debit card information, Social Security Numbers and telephone numbers.
HOW INFORMATION IS COLLECTED
VirtualAd collects Personally-Identifiable Information directly from you when you choose to provide it to us, our clients or partners. For example, VirtualAd collects Personally-Identifiable Information when you submit personal information to us via the Contact Us form (or similar forms) on our Website. In addition, VirtualAd may collect or receive Personally-Identifiable Information from its clients or partners in connection with its provision of the Services.
VirtualAd is in compliance with the online industry’s self-regulatory rules pertaining to the collection and use of non-HIPAA related healthcare information. VirtualAd will only collect sensitive health care information when a user consents or opts-in to such collection.
HOW WE USE THE INFORMATION
VirtualAd uses the Personally-Identifiable Information it receives from visitors to the Website for internal purposes, including marketing of its products and services. VirtualAd uses the Personally-Identifiable Information it receives from clients or partners for lawful purposes related to its provision of the Services. In addition, VirtualAd, our third party service providers, clients and partners may use the information we collect for a number of marketing or advertising purposes, including “Interest-Based Advertising.” The goal of Interest-Based Advertising is to deliver more relevant marketing messages and advertisements based upon an individual’s online activities and interests. VirtualAd, its third party service providers, and partners gather information about your online activities across the Sites and other internet sites or mobile apps, and supplement such information with information from clients or third parties (such as parties that perform web analytics) in order to make inferences about your consumer and other interests. We then use this information to create customized or targeted advertising campaigns for our clients, as well as for other marketing-related purposes. VirtualAd reserves the right to combine this Non-Personally Identifiable Information with data collected or received from other sources to create a database of consumer and other data (i.e., “aggregated data”), and to use such aggregated data for a variety of purposes, including for unrelated advertising, marketing and analytical activities. VirtualAd is not responsible for, and, with limited exceptions, does not control, the collection of data from third party sources. If you wish to opt out of the collection of your information by third parties, you must contact those parties directly.
INFORMATION SHARING AND DISCLOSURE
VirtualAd does not sell or share your Personally-Identifiable Information with unaffiliated third parties without your consent. It uses Personally-Identifiable Information for a number of client-authorized purposes, such as reporting on the effectiveness of advertising campaigns and connecting a user’s online information with offline customer data supplied by the client, and customizing the advertisements delivered to those users. VirtualAd also uses the anonymous aspects of Personally-Identifiable Information, such as gender and geographic location, in connection with marketing to other users.
In the event VirtualAd is acquired by or merged with another company, we reserve the right to transfer or assign the Personally-Identifiable Information and Non-Personally Identifiable Information we have collected from you as part of such merger, acquisition, sale, or other change of control.
We reserve the right to use and disclose any information about or relating to you, including any Personally-Identifiable Information, to third parties without your consent if we reasonably believe that such action is necessary to: (1) comply with a court order, search warrant, subpoena, or other legal process; (2) to comply with legal, regulatory or administrative requirements of any governmental authorities; (3) otherwise fulfill a government or law enforcement request for information; (4) establish, defend or exercise our legal rights; (5) protect or defend our subsidiaries and affiliates, and all of their respective officers, directors, employees, attorneys, agents, contractors, licensors, and partners, in connection with any actual or alleged legal action, claim or dispute; (6) respond to claims that any posting or other content of the Sites violates the rights of third parties, including without limitation providing information necessary to satisfy the notice and counter-notice procedures pursuant to the Digital Millennium Copyright Act; (7) in an emergency, to protect the health and safety of our Site’s users or the general public; or (8) enforce compliance with our Terms and Conditions or other contractual obligations.
OPT-OUT PROCEDURES, ADCHOICES AND “DO NOT TRACK” SIGNALS
You may opt-out of VirtualAd’s collection and use of your information for Interest-Based Advertising purposes by emailing email@example.com. Please note that your opt-out choice is applied only to the browser from which you make the choice. You may also opt out of the collection of Interest-Based Advertising data by members of the Digital Advertising Alliance by visiting the Consumer Choice Page at www.aboutads.info/choices, and from members of the Network Advertising Initiative by visiting www.networkadvertising.org/choices.
CHILDREN UNDER 13
VirtualAd does not knowingly collect and does not wish to obtain Personally-Identifiable Information or other information from individuals under the age of 13. We also do not knowingly solicit or contact children under the age of 13, and we do not knowingly allow children under the age of 13 to use the Website. If we are notified of the receipt of Personally-Identifiable Information from an individual under the age of 13, or otherwise become aware of this, we will take reasonable steps to delete that information in accordance with applicable law. If you are the parent or guardian of a child under the age of 13 and you believe your child has provided personal information without your consent that you would like us to delete, please contact us at firstname.lastname@example.org or by writing to us at: VirtualAd Inc., 2201 – 428 Sparks St. Ottawa ON K1R 0B3.
ONLINE INDUSTRY SELF-REGULATION
VirtualAd self-regulates pursuant to the Digital Advertising Alliance’s principles applicable to Interest-Based Advertising, to the extent our activities are covered by such principles. For more information about the Digital Advertising Alliance, the self-regulatory principles and the AdChoices program relating to privacy and Interest-Based Advertising, please see the Digital Advertising Alliance’s website, www.digitaladvertisingalliance.org/. Information about the Network Advertising Initiative’s Code of Conduct and its members can be found at www.networkadvertising.org/.
VirtualAd respects the intellectual property rights of others. It is our policy to respond promptly any claim that content on the Site infringes the copyright or other intellectual property infringement of any person. VirtualAd will use reasonable efforts to investigate notices of alleged infringement and will take appropriate action under applicable intellectual property law and this policy where it believes an infringement has taken place, including removing or disabling access to the content claimed to be infringing.
To notify VirtualAd of a possible Infringement you must submit your notice in writing to the attention of “Copyright Infringement” care of email@example.com and include in your notice the following information: (a) your name, address, telephone number, and email address (if any); (b) a description of the copyrighted work that you claim has been infringed; (c) a description of where on the site the material that you claim is infringing may be found, sufficient for VirtualAd to locate the material (e.g., the URL); (d) a statement that you have a good faith belief that the use of the copyrighted work is not authorized by the copyright owner, its agent, or the law and is not a fair use; (e) a statement by you under penalty of perjury that the information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf; and (f) your electronic or physical signature. Please note that you may be held accountable for damages (including costs and attorneys’ fees) for misrepresenting that any content is infringing another’s copyright.