Privacy Policy

Effective 01 Jan 2012

ABOUT KOMLI MEDIA Inc. & THE CONTENT OF THIS PRIVACY POLICY.
Komli Media Inc. (“Komli”) is Asia Pacific’s leading digital media network platform enabling advertisers and marketers across the region to communicate with their audiences and helping publishers to grow their revenues with better optimization and campaign planning. We are headquartered in the US, with an office in California and several international offices. We provide this privacy policy (“Privacy Policy”) so that we may inform you about how our ad optimization technology, including our Ad Network Platform for online advertisers including Real-Time Bidding Service (collectively, the “Service”) gathers and processes information on behalf of (i) advertisers, agencies and ad networks, and any other media-buying clients (collectively “Demand Partners”); and (ii) website owners, mobile application owners, ad networks, ad exchanges, sell-side platforms and any other suppliers of advertising inventory for sale (collectively “Supply Partners”); wherein Demand Partners and Supply Partners in (i) and (ii) above together are “Clients”. This policy also outlines our privacy practices on our corporate Website (“Website”), komli.com.

After reviewing the Privacy Policy, if you have any further questions, please contact us at privacy@komli.com.

Komli’s products and services are designed to help Demand Partners optimize deliveries and ROI on their ad campaigns and help Supply Partners maximize revenue earned on every single impression. We are a Demand Partner focused company, but at the same time we maintain client relationships with certain Supply Partners. Ad creatives that you see come from these Demand Partners and usually the ad comes from Komli’s ad server running on atomex.net domain, or from the same domain as the Demand Partner or the Supply Partner. Generally, a user will encounter an ad from one of our demand partners by viewing the content on a website owned or operated by one of our Supply Partners.

A GENERAL NOTE ON INTERNET TECHNOLOGIES AND PRIVACY
Before you review this Privacy Policy, we recommend you are familiar with the following concepts and terms so that you can best understand how Komli and its Clients use data about you and other Internet users to display better, more interesting advertising to you as you browse the Internet.

Ad Tags: Ad Tags are pieces of code that allow the delivery of online advertisements in the dedicated ad spaces on websites and in online applications. Komli Ad Tags may transmit certain anonymous information about the web site, section of the site and size of the ad that we are optimizing.

API: An application programming interface or “API” is a particular set of rules and specifications that allows one software program to access and make use of another software program. It helps facilitate the interaction between applications, similar to the way the user interface facilitates interaction between humans and computers. Komli uses API to make a bid request on RTB inventory sold by Supply Partners.

Cookies: Cookies are small text files that web servers typically send to users’ computer when they visit a website. Cookies can be read or edited when the user loads a website or advertisement from the domain that wrote the cookie in the first place. Cookies are used by companies to collect and send information about a user’s website visit – for example, number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. This information can be used to improve a user’s online experience by saving passwords, or allowing companies to track and improve website loading times, for instance. Cookies can also be used to track a user’s browsing or online purchasing habits and to target advertisements to specific users. Cookies cannot be used to access any other data on a user’s hard drive, to personally identify them, or to act like malware or a virus. Users who prefer not to accept cookies can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive. You can read more about cookies at http://www.allaboutcookies.org/cookies/.

Personally Identifiable Information: We define personally identifiable information (or “PII”) as “information that can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual.” e. g. name, address, social security number, e-mail address etc. This is the common industry definition used by most Internet companies. Information that is collected by various Internet companies but which does not qualify as PII is call “non-PII.”

Real-Time Bidding: Real-Time Bidding (or “RTB”) is a method of buying online or mobile advertising inventory by responding in real-time to an ad call with a “bid,” usually priced by cost per thousand impressions (“CPM”), to buy that single impression and thus the opportunity to display an ad to that user. RTB buyers use multiple different data sources, including third parties, to more precisely target the ads they display.

Web Beacons & Pixels: A web beacon consists of a small string of code that represents a graphic image request on a web page, a page in an online application, or in an email. A graphic image can be associated with the web beacon, but is not required. When an image is present, usually the image is designed to blend into the background of the web page, application, or email in which it appears. Often a beacon will be placed by an online data collecting company without an image, so it is invisible to the user, and in the smallest discrete space possible on the screen. This is a “pixel” and is essentially an invisible web beacon. Pixels and web beacons can be used for site traffic reporting, unique visitor counts, advertising auditing and reporting, personalization, and other uses. They do this typically by writing or editing cookies on each user’s computer. Therefore, like cookies, they cannot be used to key log, copy personal files from your computer, or replicate like a virus. Most pixels and web beacons, including those used by Komli, collect only anonymous data. However, some may be used to collect PII, particularly in the case of email that contains a web beacon. In such cases, the data collected through the web beacon may be linked to the recipient’s email address or other information identifying the recipient.

KOMLI’s SERVICE & THE DATA IT COLLECTS

We Do Not Collect Personally Identifiable Information.
We do not collect PII via our Service, and expressly forbid our Clients from sending us PII and also take all precautions to avoid receiving PII from our Clients. If, despite these measures, we do receive PII from a Client or we inadvertently send PII we have received from a Client to a third-party we shall take all measures to remove the PII from our servers and records and to make certain the third parties have removed the PII from their records as well.

We Collect Non-Personally Identifiable Information About You.
We collect Non-PII via our Service, including but not limited to your IP host address, the date, time, and time zone of the ad request, pages viewed, browser type, the referring URL, and your computer’s operating system.

We Use Cookies And Web Beacons And So Do Our Clients.
We use cookies and web beacons for select purposes. We use them in order to track when we deliver an advertising impression so that we can correctly credit it to a Demand Partner and invoice that Demand Partner. We also drop a cookie for counting frequency of exposure to a particular ad to meet a Demand Partner’s campaign objective around frequency capping. As a buyer of RTB inventory available for sale on sell-side platforms and exchanges (Supply Partner), we do map anonymized user identification number (“UID”) against Supply Partner’s anonymized UID so as to gain handle to the underlying impression and be able to serve appropriate ad on that impression.

You Can Opt Out
Komli does perform behavioral targeting, retargeting or interest-based advertising on its owned and operated ad serving platform hosted on www.atomex.net. So if you want to opt-out of this behavioral or interest based targeting, you can simply click on the opt-out button available here. Here is some general information about the cookie opt-out http://www.worldprivacyforum.org/cookieoptout.html

Please note that if you opt-out but later delete, block or otherwise restrict cookies, Komli opt-out may not function as desired. Even if you have opted out once, if you later access the website from a different computer or Internet browser, you would need to opt-out in that environment as well as opt-out is browser and computer-specific. Deleting a cookie or opting-out does not mean you will no longer receive online advertising; it only means that you will not see targeted ads.

Being in the ad network business, Komli also uses various 3rd party ad platforms. Some of these 3rd party platforms do offer behavioral targeting solutions by dropping a cookie on user browsers from their respective ad serving domains. In such cases, Komli defers to the privacy policies of these respective platforms.

Opting out implementation at Komli Ad network
As a user privacy choice, you can choose to opt-out of the interest based behavior targeting done by Komli Ad network by clicking here. Once you opt out of online behavioral advertising Komli will honor your choice and stop using the information we collect about you to serve you targeted ads or personalized content.

However, it is important to understand the following about opt-outs:

  • Opt-out does not block Ads – If you opt-out, you will continue to see online Ads from Komli Ad network but those will not be interest based targeted ads.
  • Opt-out does not block data collection – If you opt out, Komli can continue to collect data about your browsing activity which helps Komli to serve you Ads and support other services. But in no way can Komli use that data to serve you targeted ads or personalized content.
  • Opt-outs will be annulled once you delete Komli opt-out cookies – Your opt-out is recorded by Komli using opt-out cookies which are stored in your machine. Once you delete that cookie, you will no longer be opted-out and Komli will again start showing you targeted ads until you explicitly opt-out again.
  • Opt-out duration is for 5 years – If you opt-out of Komli Ad network, then as per NAI guidelines you will remain opted-out of targeted advertising by Komli for five years from the day you opt-out notwithstanding section 3 above. After five years you will be again targeted for interest advertising until you explicitly opt-out again.
  • Opt-out is browser specific – Your opt-out action is browser specific which means that you will not be shown targeted ads on the browser from which you have opted out. Hence if you are using multiple browsers, you have to opt-out using each browser.

Opting Out Through The Network Advertising Initiative
You can also opt out of receiving cookies from some 3rd party and any other Network Advertising Initiative (NAI) compliant company by clicking here: http://www.networkadvertising.org/managing/opt_out.asp. You will find a mechanism to opt-out from Non-PII collection by a number of different Demand Partners and other Internet companies, including third-party data providers.  If you opt-out through the NAI, please refer to the FAQ available on the NAI website to understand how their opt-out mechanism.

KOMLI’s SECURITY & STORAGE PROCEDURES FOR YOUR DATA
Komli is conscious of the importance of your data to you and conscientious about protecting that data from loss, theft, or misuse. All of the non-PII data collected by Komli is stored using the same security measures that we use to protect our own proprietary corporate data. Only authorized users are able to access the data we collect and store. While we cannot absolutely guarantee the security of the data we store, we do use all commercially reasonable measures to protect this information.
We retain the Non-PII collected via our Service at a user level for certain period in order to ensure that our Service is functioning properly. We retain data at an aggregated level – so that no individual user, albeit anonymous, could be picked out from the data – indefinitely for purposes of reporting and system analytics. If you have any questions about our security practices, please send an email to us at privacy@komli.com.

KOMLI’s INFORMATION SHARING
Unless you otherwise permit Komli to share the Non-PII information it has collected about you, it will only share that information with the following third-parties and in the following circumstances: (i) to the appropriate authorities when we reasonably believe we are obligated to do so by law, or in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person; (ii) to a court of law, arbitration panel, or similar body to enforce or protect our rights either under law or as granted by an agreement; (iii) to the company or entity that acquires all or substantially all of Komli’s assets, including if the acquisition occurs as the result of Komli’s bankruptcy; or (iv) to third parties that help us provide the Service to Clients, that act as Supply Partners on our RTB service, or that enter into strategic partnerships with the company which allow us to expand the Service for our Clients.

CHILDREN UNDER 13 YEARS OF AGE
Komli’s advertising products and the Service are not intended for persons under 13 years of age, and are not intentionally developed for or directed to children. We do not knowingly solicit or collect any personally identifiable information from children under the age of 13, nor do we knowingly market our products or services to children under the age of 13.

CHANGES TO KOMLI’s PRIVACY POLICY
We may revise this Privacy Policy at any time. Any changes and/or updates to the Privacy Policy will be updated directly on this page. We encourage you to visit this page periodically to review our current Privacy Policy so that you will always know what information we gather and how we may use that information. In the event we make any material changes to this Privacy Policy we will advise our Clients of those changes in advance.

CONTACTING US
Should you have any questions in regards to this Privacy Policy or Komli’s privacy practices, please contact our representatives at the following email and they will be more than happy to clarify and assist you in any way possible: privacy@komli.com, or by mail at:
Komli Media Inc.,
c/o Privacy, PO BOX 7052,
Redwood City, CA 94063, USA.