CONSUMER PRIVACY

I. INFORMATION WE COLLECT: INDIVIDUAL INTERNET CONSUMERS

A. Personally Identifiable Information (PII).
The ValueClick Network sites are designed to promote and facilitate the business of the ValueClick companies with advertisers and marketers. These sites are not directed towards individual Internet consumers nor do they seek any PII from such consumers. PII may be collected should a consumer contact a ValueClick company on his/her own initiative or respond to a ValueClick advertisement and provide any PII. Under no circumstances does the ValueClick Network request or collect sensitive PII such as an Internet user's medical/health conditions; racial or ethnic origin; political, religious or philosophical beliefs or affiliations; trade union membership or sex life.

B. Non-Personally Identifiable Information (Non-PII).
When a consumer responds to or views an Internet advertisement served by a ValueClick company (such as through third-party Web sites or email solicitation) or visits a ValueClick Network site, we send a cookie and/or gif file ("Cookies") to assign an anonymous, unique identifier to the end user's Internet browser. Cookies are small data files commonly used on the Internet to help optimize and personalize the Internet end user experience and identify repeat visitors to Web sites.

The function of these Cookies is to provide ValueClick with information for the purpose of paying third-parties commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser's Web site; and also to optimize and personalize the Internet user's experience. If the Internet user re-visits the advertiser's site directly, ValueClick is able to continue to track the user's activities on the advertiser's site and reward the third-party Web site that referred the user. We reserve the right to retain all ad delivery and reporting data as long as may be reasonably necessary for accounting and audit purposes.

Like most standard Web site servers, we use log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, and date/time stamp. We use the information to analyze site usage, administer the site, understand usage and navigation trends in aggregate, and determine the relevance of content. This information, however, is not linked to any personally identifiable information.

We also may use Internet browsing and online purchase data associated with an anonymous identifier to develop a predictive statistical user profile of the end user's needs and interests. ValueClick does not use Cookies or log files to collect end users' names, physical addresses, email addresses, phone numbers, credit card numbers, social security numbers, or any other information which can be used to identify a specific person. We may match the IP address and user profile with email address data obtained separately in order to better target campaigns to meet user's interests, but will not share this information with third parties.

For improved audience targeting, some ValueClick Network sites use marketing technology that allows advertisers to add non-personally-identifying demographic information, such as age, gender, area code, or ZIP code, to the non-identifiable profile data. Thus, there is no direct connection between an end user's online choices and his or her personal identity.

In some cases, ValueClick receives and records partial email addresses of Internet users, only in circumstances where the user voluntarily provided its identity and contact information through the Advertiser's site or third-party marketer's site. This partial email address does not enable ValueClick to personally identify an Internet User.

II. INFORMATION SHARING

The ValueClick Network may make any PII provided in responding to an advertisement available to the company sponsoring the advertisement, as well as to other trusted third parties in accordance with the terms of this privacy policy. As a result, you may receive information on additional products, services and offers that may be of interest to you.

The ValueClick Network and/or our marketing partners may enhance and/or merge PII about consumers who have opted-in to receive marketing communications with commercially-available third party data collected from other sources in an effort to ensure that the messages being sent to the consumer in online and/or offline marketing programs are relevant to their interests. In the event we enhance and/or merge such personally identifiable information with data collected from other sources, we will take reasonable steps to maintain the integrity and quality of that information.

The ValueClick Network may share PII (including information that has been enhanced with information from other sources) with advertisers, third party marketers, our affiliated entities for their online and/or offline marketing programs or in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of any of the ValueClick Network companies. While ValueClick strongly encourages clients and partners to adopt responsible approaches to online marketing, ValueClick is not responsible for the information practices of clients or their partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from ValueClick's policy.

The ValueClick Network may release account and any other personal information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law;  or protect the rights, property, or safety of ValueClick or others. This includes exchanging information with other companies and organizations for fraud protection.

III. CONSUMER CHOICE AND ACCESS

A. Opting Out.
Some ValueClick Cookies have an "opt-out" option. This process does not remove the ValueClick Cookie from your system; it simply replaces it with an opt-out Cookie that does not contain any unique identifiers. If this site provides such a process it is detailed below.

Some of ValueClick's Cookies do not have an "opt-out" option, yet you still have the option of blocking the use of Cookies by changing a setting in your Internet browser. Please see your browser supplier's Web site for details on how to do this.

This site does not maintain a process for an individual consumer to opt-out of a ValueClick ad serving Cookie.

B. Accessing Consumer Information.
Because they are not directed towards individual Internet users, most ValueClick Network sites do not maintain a process for an individual consumer to review and/or request changes to any PII collected. If this site provides such a process it is detailed below.

Except as provided below, this site does not maintain a process for an individual consumer to access his/her PII.

IV. SECURITY

The ValueClick Network employs industry standard security measures to ensure the security of all data. Any data that is stored on ValueClick's servers is treated as proprietary and confidential and is not available to the public. ValueClick has an internal security policy with respect to the confidentiality of customer and other data, allowing access only to those employees or third parties who have a need to know such information for the purpose of effectively delivering ValueClick products and services by means of user login and password requirements. The ValueClick Network routinely evaluates its data security practices to identify security threats or opportunities for improvement.

No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of ValueClick to intercept or access transmissions or private communications unlawfully. While we strive to protect your PII, ValueClick cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with a ValueClick Network company.

The ValueClick Network is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to prohibit the sending of unsolicited or "Spam" e-mail by ValueClick or any of its marketing partners.