Qualia Online Privacy Policy

Last Updated: February 1, 2018 (this is the date of the most recent version of our policy.) We will modify the policy from time to time. Please check back for updates.

Qualia is a technology company that offers a platform enabling websites and advertisers to recognize devices (i.e., computers, mobile phones & tablets) 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 Qualia’s audience association platform (the “Platform”). This privacy policy also covers the information collected by this website, located at http://qualia-media.com (the “Website”). A common complaint about privacy policies is they can be long, difficult to understand and include too much “legalese”. We have tried to explain what we do in simple, understandable language. We welcome your comments.

We want to be transparent about what we do and how we do it and most of the rest of this privacy policy is about that, but if you just want to cut to the chase and stop Qualia from collecting data about your computer, tablet or mobile device via our audience association Platform, click here to opt-out. If you opt-out, you’ll still receive ads, they just won’t be tailored to your interests by Clients utilizing our Platform.

Our Website

Our Website is primarily directed to our Clients and prospective Clients. We don’t typically collect personally identifiable information (“PII”) via the Website unless it is provided to us. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone number, or email address. For example, sometimes prospective Clients come to our Website and fill out a form so that our sales team can get in touch with them. We use this information only to respond to these requests or inquiries. We do not provide this information to third parties unless we need help with the request, likely because they can do it better or faster.

Qualia also collects non-personally identifiable information (“Non-PII”) from visitors to this Website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer or mobile device’s operating system.

If you are a Qualia Client and/or visit the Qualia Website, maybe you don’t want us to contact you for marketing purposes. If that is the case, let us know by email, mail, fax or phone. The easiest way to opt-out of receiving these emails is to contact us by email at info@qualia-media.com.

Cookies

Our Website uses cookies (small text files maintained by your browser) in order to help manage our relationship with visitors to the Website, to improve the Website and for site analytics purposes. For more information about cookies, please visit http://www.allaboutcookies.org/cookies/.

Our Technology Platform

Overview of the Platform

The basis of our business is helping advertisers, advertising networks, online merchants and websites (our “Clients”) do a better job of engaging with their customers and prospects (their “Users”). We do this by recognizing and collecting information about the various computers, mobile devices, tablets, and game consoles (“Screens”) that people use to connect the Internet. This data is collected as Users visit websites, mobile applications and other digital media properties (“Sites”) where our technology is enabled. The data we collect about these Screens is designed to be utilized by our Clients on the Platform for the following: to enable ad delivery and reporting across Screens, to deliver more relevant advertising to their Users, and to measure the effectiveness of advertising.

Information Collected via the Platform

Qualia’s Platform enables our Clients to recognize Screens when their Users visit Sites. In order to do this, we collect information about User’s computers, mobile devices, tablets, and game consoles (“Screens”). The type of information collected via the Platform includes the type of Screen, IP address, browser version, time zone, the fonts installed, browser plug-ins and various other properties of a Screen. Qualia does not collect PII in connection with the Platform.

How Information is used on the Platform

The information collected via the Platform is put into a “snapshot” and is sent to our servers each time a User visits a Site where our technology is enabled. 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 Platform 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.

Cookies & Web Beacons

Our Platform utilizes cookies. We don’t depend on cookies to recognize browsers. However, in certain cases we may use cookies, and HTML5 to speed up the process of recognizing a computer, tablet, mobile device or game console. This allows us to identify a Screen faster and more efficiently. We don’t store any PII in any of our cookies or similar technologies. Which of these technologies we use depends upon the particular Site that utilizes our technology.

Our Platform utilizes web beacons. A web beacon is just a link to another website that enables two sites to share information. Our Platform also uses web beacons on Sites where our technology is enabled to share information in order for our Platform to operate as described above.

Information Sharing

Qualia licenses the anonymized Screen data we collect, and algorithmically derived data representative of a consumer and/or household in connection with the audience association Platform. We may combine our data with the data of others to make us even better at recognizing Screens.

We may share information when we believe such action is appropriate to comply with the law (e.g., legal process or a statutory authorization); to enforce or apply our customer agreements; to initiate, render, bill, and collect for services; to protect our rights or property, or to protect users of those services from fraudulent, abusive, or unlawful use of, or subscription to, such services; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of information without delay.

We may transfer information to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Qualia is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a 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.

Data Security, Integrity and Retention

The security of your information is important to us, including but not limited to the PII collected via the Website. Qualia has implemented reasonable security measures to protect the information, both during transmission and once it is received. This includes but is not limited to the use of firewalls, application controls and encryption. All the people that work at Qualia and who have access to data are subject to our company’s policies that prohibit the unauthorized transmission of data to third parties. Please note that no method of electronic storage or transmission is 100% secure. And, as our lawyers point out quite emphatically and please note the capitalization for emphasis, WE WILL NOT BE LIABLE FOR ANY UNAUTHORIZED ACCESS OR USE OR ANY DAMAGES INCLUDING WITHOUT LIMITATION DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR OTHER DAMAGES CAUSED BY THIRD PARTIES.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

We store data we collect pursuant to providing the Platform for up to 90 days, and that time period is reset every time we can recognize a particular Screen within a reasonable degree of probability.

Children

The Website is designed for people over 18. We do not knowingly collect information from a Screen that is being used by persons under the age of thirteen (13). If we are made aware that we have received PII from someone under 13, we will use reasonable efforts to remove that information from our records.

Opt-out, Choice Mechanisms

Qualia wants you to be in control of your experience while online. We help our Clients provide you with digital advertising that’s meaningful and supports the Sites you use for free, so everyone wins. We offer two choice mechanisms: an opt-out mechanism as well as the ability to reset your Qualia advertising ID. If you want to exercise choice via either or both mechanisms, please click here and follow the instructions provided.

To opt-out from other companies that provide online behavioral advertising services, you can visit the following online advertising industry websites.

• The Digital Advertising Alliance, http://www.aboutads.info/choices/
• The Network Advertising Initiative http://www.networkadvertising.org/choices/

Do Not Track

Our Technology is designed to recognize a Do Not Track (DNT) signal, but we do not control how our Clients respond to DNT signals.

Privacy Groups and Self-Regulatory Membership

Safe Harbor Privacy Principles

Qualia complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Qualia has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Qualia’s certification, please visit http://www.export.gov/safeharbor/

We Self-Certify Compliance With

Digital Advertising Alliance

Qualia adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (www.aboutads.info). The DAA offers a Consumer Choice Page (opt-out) and other privacy tools and resources.

Internet Advertising Bureau

Qualia is a member of the Internet Advertising Bureau ( www.iab.net).

Newtork Advertising Initiative

Qualia is a member in good standing of the Network Advertising Initiative (NAI), and adheres to the NAI Code of Conduct. Click here to learn more about the NAI

How to Contact Us

If you have any questions or concerns regarding this statement, you have general or technical questions about our privacy practices and features or you have complaints regarding our compliance with the Safe Harbor, you should first contact our Privacy Officer at privacy@qualia-media.com or even by snail mail.

Qualia
Attn: Privacy Policy
37 W. 28th Street, 5th Floor
New York, NY 10001

Changes to Privacy Policy

This Privacy Policy may change from time to time. Our Privacy Policy was last updated on February 1, 2018.