privacy policy

OUR MISSION

August 15, 2011

33Across, Inc. ("33Across") provides marketing technology and services to website owners and online marketers (our "Clients"). Our mission is to improve the online experience by delivering more relevant advertising to consumers. We consider the protection of user privacy and anonymity to be of paramount importance, and provide this privacy policy to inform consumers about how our technology collects and uses consumer data. This policy also outlines our privacy practices on our corporate Website ("Website"), www.33across.com. If you have any questions about this privacy policy, please feel free to contact us at privacy@33across.com. By visiting the Website, you are accepting the practices outlined in this privacy policy. This privacy policy does not apply to the practices of third parties that 33Across does not employ or manage.

USER PREFERENCES MANAGER

Click here to Explore your preferences as predicted by 33Across.

PRIVACY PRACTICES FOR OUR TECHNOLOGY

OVERVIEW OF OUR TECHNOLOGY

33Across provides technology services to Clients that enable them to collect and use Social Engagement Data to improve the relevance of advertising which appears on web pages. "Social Engagement Data" consists of anonymous information regarding the relationships between people, the website pages they visit and/or the actions they take on a website, such as installing or sharing applications, widgets or other content. For example, 33Across may collect Social Engagement Data when an individual visits a Client's webpage, installs or shares an application, or connects with friends from within one of our Client(s) websites. Data is only collected from the websites of Clients who use our services.

Clients use the Social Engagement Data we capture to classify website users who are likely to share similar interests or preferences. For example, if a person expresses an interest in comedy films, our technology would help our Clients identify other people who are likely to enjoy comedy films based on similarities in Social Engagement Data between the different people. By using our technology, Clients categorize people with similar characteristics or interests, improving their ability to deliver more relevant advertising. 33Across maintains Social Engagement Data for up to 60 days for purposes of identifying people with similar characteristics or interests. After 60 days, Social Engagement Data is no longer used for these purposes, but is used for research and reporting on an aggregated basis for up to 2 years. The cookies we use to improve the relevance of advertising which appears on web pages are set to expire after 1 year.

You may encounter our technology when: you visit one of our Clients' websites; we purchase online advertisements on a website that you visit; and/or when our Clients purchase online advertisements on a website that you visit.

DATA OUR TECHNOLOGY COLLECTS FROM CLIENT WEBSITES

PERSONALLY IDENTIFIABLE INFORMATION

Personally Identifiable Information ("PII") means any data which identifies you personally, such as name, address, email, or telephone number. We do not collect PII from Client websites via our Technology.

NON-PERSONALLY IDENTIFIABLE INFORMATION

When you are on the website of one of our Clients, our technology collects Non-Personally Identifiable Information ("Non-PII"), which refers to information that cannot by itself be used to identify a particular person or entity. Non-PII includes, but is not limited to, your Internet Protocol ("IP") address, browser type (for example Internet Explorer or Mozilla), operating system (for example Windows or Macintosh), the URL of Client website pages or sections that you visit, and Social Engagement Data.

USAGE OF COOKIES

Nearly all websites, including those of our Clients, use a feature of your internet browser to set a "cookie" on your computer. Cookies are small text files that contain alphanumeric characters. The website which places a cookie on your computer can then recognize the computer when you revisit the site. This enables the site to provide services such as automatic log-on, customizable content or settings, and relevant ad delivery. Our technology uses cookies to help make the advertising you see more relevant.

You are always free to decline to receive cookies, but by doing so you may not be able to use many common website features or take advantage of targeted advertising. You can configure your browser to accept all cookies, reject all cookies, erase cookies, or notify you when a cookie is set. (Each browser is different, so check the ''Help'' menu of your browser to learn how to change your cookie preferences.)

You may click HERE to opt-out of data collection and targeting cookies from 33Across. Additionally, 33Across is a member of the Network Advertising Initiative (NAI) and is compliant with the NAI's Self-Regulatory Principles. You may click HERE to find out more about the NAI's Self-Regulatory Program and to opt out of 33Across and other NAI member company advertising programs.

Opting out does not mean you will no longer receive online advertising. It does mean that 33Across will no longer deliver ads tailored to your Web preferences and usage patterns. The 33Across Opt-out Tool is cookie-based. In order for the Tool to work on your computer, your browser must be set to accept cookies. If you buy a new computer, change web browsers or delete this cookie, you will need to perform the opt-out task again. Be advised that if you change computers or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser.

PRIVACY PRACTICES FOR OUR WEBSITE

PERSONALLY IDENTIFIABLE INFORMATION

We collect Personally Identifiable Information exclusively on the 33Across Website, www.33across.com, when you choose to provide it to us. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of the Website's features. For example, you may choose to provide us PII about yourself by sending us an email, by completing an online form, or by registering for a login and password for the services offered on this Website. We use this information only to contact you to respond to your inquiry or manage your registered account. Once collected, we will store your PII for a reasonable time for record keeping purposes and to simplify the login process if you elect that service. The information that we store is maintained as long as you are an active registered user, but may be deleted as space requires or in the normal course of business. Please note that updates on legal notices from us such as this privacy policy, will be available on this Website and will govern your use of the Website. You are responsible for reviewing such legal notices for changes.

NON-PERSONALLY IDENTIFIABLE INFORMATION

We collect Non-Personally Identifiable Information ("Non-PII") from all visitors to this Website. 33Across automatically receives and records certain Non-PII including your IP host address, pages viewed, browser type, Internet browsing and usage habits, domain name, the time/date of your visit to this Website, the referring URL and your computer's operating system. 33Across uses this Non-PII to help diagnose problems with its server, analyze trends and administer the Website.

COOKIES

We use persistent cookies on this Website in order to help us manage the opt-out process for our technology. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file. For more information about cookies please visit All About Cookies. No PII is collected by or associated with cookies from this Website. We do not combine information collected through cookies with other personal information to tell us who you are or what your e-mail address is. For information on our opt-out process, please review the section of this privacy policy entitled "Usage of Cookies" above. Some of our business partners may use cookies on our Website (for example, advertisers). However, we have no access to or control over these cookies.

THIRD PARTY WEBSITES

The 33Across Website may contain links to and advertisements for websites operated by third parties whose privacy practices may differ from ours. While we endeavor to associate only with reputable entities, 33Across cannot be responsible for the privacy practices of these other websites. We encourage you to check the privacy policies of all websites that you visit.

UPDATING / DELETING YOUR PII

Although we don't collect PII via our Technology, if you'd like us to update, correct, delete or deactivate any PII that you have provided to us on the 33Across Website, please send your request to us at privacy@33across.com. and we will process your request within a reasonable period of time after receipt. Please note that some information may remain in our records after your deletion request.

GENERAL PRIVACY INFORMATION

INFORMATION SECURITY

The security of your information is important to us, including but not limited to the PII collected via the Website. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

If you have any questions about our security practices, please send an email to us at privacy@33across.com

INFORMATION RELATING TO CHILDREN

Our products and services are designed for those 18 years of age and older. We do not knowingly collect any data from anyone under the age of 13. If we are made aware that we have received any data from anyone under the age of 13, we will use reasonable efforts to remove that information from our records.

DISCLOSURE OF INFORMATION TO THIRD PARTIES

We do not rent or share your PII with non-affiliated third parties without your consent. We may, however, share your PII with trusted third party contractors who provide services for us. These third party contractors are prohibited from using the information we provide for purposes other than performing services for us.

We may share Non-PII collected on the Website or via our Technology with unaffiliated third parties. For example, we may disclose that our online advertisements offering 'sports car' test drives receive more clicks than those offering 'Mini Van' test drives. This information is only used in the aggregate and cannot be used to contact or identify any person individually.

We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and 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.

Finally, we may transfer information, including any PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

CHANGES TO THIS PRIVACY POLICY

This privacy policy is subject to change. Use of information we collect now is subject to the privacy policy in effect at the time such information is used. If we make any material or substantive changes in the way that we use the PII collected through this Website, we will post a clear and conspicuous notice of those changes on the Website and in this privacy policy.

CONDITIONS OF USE

If you decide to visit the Website, your visit and any possible dispute over privacy is subject to this privacy policy and our terms of use, including limitations on damages, arbitration of disputes, and application of New York state law.

CONTACT INFORMATION

For questions or concerns relating to privacy, please send us an email at privacy@33across.com. Alternatively, you may contact us at the address below:

33Across Inc.
Attn: Privacy Officer
229 West 28th Street,
12th Fl
New York, NY 10001