Privacy Policy

Last updated July 19, 2011

Our Privacy Commitment

ADLY Inc. ("ADLY," "we," "us" or "our") is committed to respecting the privacy rights and concerns of all users of the ADLY (http://Adly.com) websites where this Privacy Policy is posted (the "Site(s)") (we refer to the Site(s) and the services made available through the Site(s), collectively, as the "ADLY Features"). As such, we have established and implemented this Privacy Policy to inform visitors to the Site(s) and users of the ADLY Features how we use and protect the information we collect through the Site(s). By visiting the Site(s) or using any of the ADLY Features, you consent to ADLY's collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy. This Privacy Policy is effective as of the date set forth above and is only applicable to the Site(s) and not to any other website that you may be able to access from the Site(s) which may have its own data collection and use practices and policies.

This policy answers the following questions:

What information do we collect about you and how do we use it?

Will we share your personal information with third parties?

What choices do you have about the collection and use of your personal information?

What security measures do we take to safeguard your personal information?

WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE USE IT?

Types of Information We Collect

Personal information means information that can be used to identify and contact you. You do not need to submit personal information to access certain areas of the Site(s), but if you do not want to disclose certain personal information to us, you will not be able to access certain aspects of the ADLY Features.

We collect personal information when you create an account through the ADLY Features; participate in polls, surveys, and questionnaires; participate in contests, sweepstakes, or other promotions; place advertisements on a Twitter feed, or allow your Twitter feed to be "sponsored;" or receive customer or technical support.

To create an account for the ADLY Features, we require you to provide your name, date of birth; email address, Twitter screen name, mailing address (if you choose to be paid by check) and phone number. When you are placing advertisements or selling products through the ADLY Features, in addition to the information above, we will ask for your billing address, telephone number and credit card or other payment information. You may also choose to provide us your screen names for certain instant messaging programs (such as AIM, Windows Live Messenger, Yahoo Messenger and Skype) that you may use if you would like us to contact you through IM.

Additionally, we may also collect other types of information (known as demographic information) such as your gender, hobbies, occupation, platform preferences, and other similar information. This demographic information may be associated with your personal information.

How We Use Your Personal Information

The personal information you provide to us will allow us to fulfill your advertising placements; fulfill your product sales; alert you of new products or services, features, or enhancements; handle/route your customer service questions or issues; and/or notify you of upgrade opportunities, contests, promotions, or special events and offers. We also use your e-mail address to send you messages about the ADLY Features and other general announcements. If you provide us your IM screen names, we will be able to contact you through the IM screen names that you submit, however, those screen names will not be made publicly available to other users.

We keep track of your interactions with us, including but not limited to your activity within the ADLY Features. We may use personal information that you provide to us to send messages to you in response to your request to perform an activity in connection with your use of any of the ADLY Features. We may also use your personal information to contact you when necessary.

Cookies

"Cookies" are small bits of electronic information that a website sends to a visitor's browser and are stored on the visitor's hard drive. Like many websites, we employ cookies in certain areas of the Site(s) to allow us to provide information which is targeted to your interests and to make your online experience more convenient. For example, when you return to one of our websites after logging in, cookies provide information to the website so that the website will remember who you are. Should you disable cookies in your browser, you will have to provide your user ID and password each time you log in.

Log Information

Our servers automatically record information that your browser sends whenever you visit the Site(s). This information includes your Internet Protocol (IP) address, your browser type and version, the search engine you used to find the ADLY Features, if any, the operating system your computer uses, which ADLY Features you use and when and how long you use them. We use this information to monitor and analyze how users use the ADLY Features, to provide customer service and to maintain and improve the ADLY Features.

Children's Privacy

We do not knowingly collect personal information from children under 13. We take children's privacy seriously, and encourage parents to play an active role in their children's online experience at all times.

WILL WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?

Sharing of Information

We may use your personal information to provide analyses of our users in the aggregate to prospective partners, advertisers and other third parties. We may also disclose and otherwise use, on an anonymous basis, affiliation, position, interests and other non-personal information about customers.

In addition, we will share the personal information we collect from you under the following circumstances:

Protection of rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms of Use for the ADLY Features, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the ADLY Features, or (iv) such action is appropriate to protect the rights, property or safety of ADLY, its employees, users of the ADLY Features or others.

Asset transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of ADLY's assets, user information, including personal information collected from you through your use of the ADLY Features, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Site(s).

Service Providers. We may share your personal information with service providers that we engage for the purpose of processing information on our and your behalf. For example, we may have partnered with other companies to maintain or manage the ADLY Features, fulfilling Purchase Orders for advertising or processing payments. Additionally, we may partner with other companies to process consumer surveys, fulfill prizes, or to process, analyze, and/or store data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures.

Additional Information You Should Know About Third Parties

This Privacy Policy does not cover the information practices of third party websites linked to the Site(s). Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.

When you have clicked on an advertisement or third party logo displayed on our Site(s) which links you to a different website, our Privacy Policy no longer applies and you must read the privacy policy of the advertiser to see how your personal information will be handled on their website.

WHAT CHOICES DO YOU HAVE ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION?

Control of Your Information

You may delete your account (and thus your personal information) at any time by accessing the "Delete Account" area of the ADLY Features, emailing us or notifying us by telephone. Please note that when you delete your account, we may retain your account information for a reasonable period of time afterward for the purpose of internal account management and fraud prevention activities.

Opting Out of Receiving Communications from Us

The only way for you to unsubscribe from receiving communications from us, including messages relating to your account transactions, is to delete your account.

Mediation

If you are a resident of a country outside of the European Union, you also agree that, in the event any dispute or claim arises out of or relating to this Privacy Policy, you and ADLY will attempt in good faith to directly negotiate a written resolution of the matter. You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Los Angeles, California with a mutually agreed mediator in an attempt to resolve the dispute. Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorney's fees, even if you would otherwise be entitled to them

Dispute Resolution for Residents of the European Union

If you are a resident of the European Union, in the event that you have any dispute or claim arising out of or relating to this Privacy Policy, you may report your claim to the European Union Data Protection Authorities located in your jurisdiction.

WHAT SECURITY MEASURES DO WE TAKE TO SAFEGUARD YOUR PERSONAL INFORMATION?

The personal information that you provide to us is stored on servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to ensure the security of such information. In addition, we restrict access to personal information to ADLY employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the ADLY Features. All ADLY personnel who have access to this information are trained in the maintenance and security of such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the ADLY Features and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

European Commission's Directive on Data Protection - Safe Harbor

ADLY adheres to the Safe Harbor Principles that were established by the U.S. Department of Commerce in consultation with the European Commission to comply with the European Commission's Directive on Data Protection.

Notification of Changes

This Privacy Policy may change from time to time and we will post all changes on this page.

Questions? Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at privacy@adly.com.

Terms of Use

Please read the ADLY Inc. Online Terms of Service governing the use of the Site(s) and the ADLY Features.