Kepler Group LLC Privacy Policy

Updated February 2016

Kepler Group (“we” or “us”) is a marketing services company. Kepler Group provides strategic guidance, as well as executes and optimizes media buys on behalf of online advertisers. We license and operate technology (“Platform”) that enables the buying and selling of online advertising. We provide this privacy policy so that we may inform you about how we process information on behalf of the advertisers we serve, and other businesses that use our services (“Clients”). This policy also outlines our privacy practices on our corporate website (“Websites”), www.keplergrp.com. If you have any questions about this privacy policy, please contact us at privacy@keplergrp.com.

Privacy as it relates to Platform:

PERSONALLY IDENTIFIABLE INFORMATION

We don’t collect Personally Identifiable Information (“PII”) of any kind via the Platform, and take reasonable measures to avoid receiving PII from Clients via the Platform. PII includes data such as your name, address, phone number, social security number, or email address.

NON-PERSONALLY IDENTIFIABLE INFORMATION

We do collect Non-Personally Identifiable Information (“Non-PII”) via the Platform, including but not limited to an Internet user’s IP host address, pages viewed, browser type, the URL, the referring URL, Internet Service Provider, and his or her computer’s operating system. We also obtain information from 3rd party data providers who collect and make available information such as behavioral, contextual, and demographic data. For example, if you visit a number of travel websites, a 3rd party data provider may flag you as being interested in taking a vacation.

COOKIES AND CLEAR GIFS

We use cookies in conjunction with clear GIFs (also known as “web beacons” or “pixel tags”) in our Platform in order to help make the online advertisements you see more relevant to you. We also use cookies and clear GIFs to help our clients make advertising more relevant. Further, these technologies are also used to measure the success of our Clients’ online advertising campaigns. For more information about cookies and clear GIFs please visit http://www.allaboutcookies.org/cookies/

TO OPT OUT OF COOKIES

If you choose not to take advantage of cookies, you may follow a simple procedure to “opt out” of the targeted advertising provided by Kepler Group and other online advertising companies. You may do so through the NAI Global Opt-out (http://www.networkadvertising.org/choices/) or through the DAA’s site (http://aboutads.info).

At Kepler Group we use MediaMath’s TerminalOne as our primary ad buying platform. Therefore, if you would like to opt out of the targeting advertising we provide – please note that as you make your “opt out” choices.

If you delete, block, or otherwise restrict cookies (or if you use a different computer or Internet browser), you may need to renew your opt-out choice.

Privacy as it relates to our website:

PERSONALLY IDENTIFIABLE INFORMATION

We do not collect personally identifiable information on our web site.

NON-PERSONALLY IDENTIFIABLE INFORMATION

We collect 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 browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system. We use this information to understand our Website traffic and for maintenance of the Website.

General privacy information

INFORMATION SECURITY

The security of your information is important to us. 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 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@keplergrp.com

INFORMATION RELATING TO CHILDREN

Our products and services are designed for those 18 years of age and older. We do not knowingly collect PII from anyone under the age of 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.

DISCLOSURE OF INFORMATION TO THIRD PARTIES

We may share Non-PII collected via the Platform with Clients. Similarly, we may enhance the Non-PII collected via the Platform with Non-PII collected from Clients.

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 to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

STORAGE OF INFORMATION

We don’t collect PII via the Platform. We retain the Non-PII collected via the Platform for up to three years.

CHANGES TO THIS PRIVACY POLICY

This privacy policy is subject to change. 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.

CONTACT INFORMATION

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

Kepler Group LLC, Privacy Officer
6 East 32nd Street, Floor 9
New York, NY 10016