This Customer Privacy Policy of PLYmedia Inc. and its consolidated subsidiaries (“Company”) covers the collection, use, and disclosure of personal information that may be collected by the Company arising from or related to the ADK2 platform, including anytime you interact with the Company, such as when you visit our website, when you sign up as a client or as a publisher on the ADK2 Platform, or when you speak with our sales representatives or associates. Please take a moment to carefully read the following to learn more about our information practices, including what type of information is gathered, how the information is used and for what purposes, to whom we disclose the information, and how we safeguard your personal information. Your privacy is a priority at the Company, and we go to great lengths to protect it. This policy does not cover the practices of companies that we does not own or control, or to people that we do not employ or manage

1. Reasons the Company Collects Personal Information

We collect your personal information because it helps us assure quality of service and enrichment of the ADK2 offerings.

2. Information Collected and How Information May be Used

There are a number of situations in which your personal information may help us run the Platform or enhance it. For example:

We ask for your personal information during the application process to become a registered user and if you register and use our Platform, including but not limited to User Name, Password, First and Last Name, Email Address, Country and other identifying information, including financial data to permit for processing and tracking payments.  We may also collect such information whenever you interact with the Company and voluntarily disclose such information to us.

We also may collect information for market research purposes to gain a better understanding of our registered users and thus provide more valuable service.

We collect information regarding your activities on our Platform to provide our services, to maintain or improve the Platform and services, and to provide an appropriate end-user experience.

We may use personal information to provide the services that you have requested, as well as for auditing, research, and analysis to maintain or improve our Platform and services.

This information may be shared with third parties or in special circumstances as described elsewhere in this Policy.

3. When the Company Discloses Your Information

The Company takes your privacy very seriously. The Company does not sell or rent your contact information to other marketers.

To help us provide our service, your personal information may be shared with legal entities within our corporate group globally who will take steps to safeguard it in accordance with this Policy.

There are also times when it may be advantageous for the Company to make certain personal information about you available to companies that the Company has a strategic relationship with or that perform work for the Company to provide products and services to you on our behalf. These companies may help us process information, including financial information, and process payments, render the services to you via the Platform, manage and enhance customer data, provide customer service, assess your interest in our Platform and services, or conduct customer research or satisfaction surveys.  In such situation these companies are prohibited from using your personal information for any unauthorized purposes and are also obligated to protect your information in accordance with the Company’s policies, except if we inform you otherwise at the time of collection. Without such information being made available, it would be difficult for you to use the Platform, for us to deliver our services, for you to receive customer service, provide us feedback to improve, or access certain features of the Platform or services.

We also reserve the right to disclose your personal information for any reason if, in our sole discretion, we believe that it is reasonable to do so, including law enforcement, litigation or to satisfy laws, regulations, or governmental or legal requests for such information. We may also disclose personal information that is necessary to identify, contact, or bring legal action against someone who may be violating our contracts, policies and procedures. Finally we may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary.

4. How the Company Protects Your Personal Information

The Company takes precautions—including administrative, technical, and physical measures—to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.

Our websites use Secure Sockets Layer (SSL) encryption on all web pages where personal information is required in order to protect the confidentiality of your personal information while it’s transmitted over the Internet. You can help us by also taking precautions to protect your personal data when you are on the Internet. Change your passwords often using a combination of letters and numbers, and make sure you use a secure web browser.

While we make every effort to ensure the integrity and security of our Platform and systems, no security measures, however thorough, are perfect and there can be no absolute assurance of security.  Therefore, we cannot and do not offer an absolute guarantee or warrant the security of the information we possess.

5. Integrity of Your Personal Information

The Company has safeguards in place to keep your personal information accurate, complete, and up to date for the purposes for which it is used. You have the right to access and correct the personal information you have provided by contacting us at privacy@PLYmedia.com.

6. Privacy of Children

Protecting children’s privacy is especially important to us. We do not knowingly collect personal information from children under 13. If a child under 13 submits personal information to the Company and we learn that that personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. Therefore we restrict our website to persons 18 years or older.

YOU MUST BE EIGHTEEN (18) YEARS OR OLDER TO ACCESS THE COMPANY’S WEBSITE. IF YOU ARE UNDER EIGHTEEN YEARS OF AGE, YOU ARE NOT PERMITTED TO ACCESS THE PLATFORM FOR ANY REASON. DUE TO THE AGE RESTRICTIONS FOR USE OF THE PLATFORM, NO INFORMATION OBTAINED FROM USE OF THE PLATFORM FALLS WITHIN THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT OF 1998 AND IS NOT MONITORED AS DOING SO.

7. Cookies and Other Technologies

As is standard practice on many corporate websites, our website uses “cookies” and other technologies to help us understand which parts of our websites are the most popular, where our visitors are going, and how much time they spend there. We use cookies and other technologies to study traffic patterns on our website, to make it even more rewarding as well as to study the effectiveness of our customer communications. And we use cookies to customize your experience and provide greater convenience each time you interact with us.

If, however, you prefer not to enable cookies, please click here to disable cookies. Please note that certain features of our website will not be available once cookies are disabled.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. The Company will not use the information collected to market directly to that person.

In addition we may use pixel tags—tiny graphic images—to tell us what parts of our website customers have visited or to measure the effectiveness of searches customers perform on our site.

8. Commitment to Your Privacy

As we said, the Company takes protecting your privacy very seriously. To make sure your personal information is secure, we communicate these guidelines to our employees and strictly enforce privacy safeguards within the company.

9. International Users

For customers outside the United States, we transfer your personal information as described in this Privacy Policy to the United States, where it is processed, collected and stored using Amazon Web Services, Inc., (“AWS”) a subsidiary of Amazon.com, Inc. or its affiliates.  The AWS Customer Agreement can be found here.  We take adequate measures to ensure the privacy of data subjects, and except as set forth in this Privacy Policy, we will not transfer your data to any other person, whether in the United States or in another country.  We have submitted to be registered with the Israeli Registry, The Israeli Law, Information and Technology Authority (ILITA).  More information on ILITA can be found here.

10. Further Questions Regarding Privacy

If you have questions or concerns about the ADK2 Customer Privacy Policy or data processing, please contact us at privacy@plymedia.com

11. Effective Date; Updates to Privacy Policy

From time to time we may make changes to this Policy and publish the same prominently on our website with the date of last update. These changes will supersede any prior changes. You understand and agree that we will treat your continued use of our Platform or services after such changes have been published as your acceptance of the updated Policy.

LAST UPDATED: March 2013