Before reviewing these suggestions please note that AdLib cannot provide legal advice or counseling to clients, and that includes specific advice about clients' privacy policies. This document is not a substitute for professional legal advice. This document does not create an attorney-client relationship, nor is it a solicitation to offer legal advice. Each client should consult its legal counsel for advice regarding its individual situation. This document contains suggestions for good privacy practices and is provided solely for your convenience without any guarantees or warranties of any kind. These suggestions, and your decision to follow or not follow them will in no way relieve you of any contractual or legal obligations to AdLib or any third parties.
Why a privacy policy is needed:
Because your AdLib campaigns require access to certain types of tracking, the Digital Advertising Alliance Self-Regulatory Program (enforced by the Better Business Bureau and the US Federal Trade Commission) requires that you let your visitors know.
Clients should at all times post a conspicuous privacy policy on their website(s) that is in accordance with all applicable laws, regulations and industry guidelines.
You may want to discuss your privacy policies and practices with your clients and partners as well.
Where to place the privacy policy:
A link to your privacy policy should be clearly visible on all site pages where you collect personal information and have your AdLib tag.
Privacy Policy Guidelines and Requirements:
1. Make a good faith disclosure of the fact that you are collecting data about consumers that may be used for advertising. You should provide a clear, meaningful, and prominent notice that you are collecting data for the purposes of advertising. This notice should include disclosures, amongst any others you deem necessary or appropriate, concerning:
The types of data collected
The types of technology used. Many clients aim to strike a balance between offering an exhaustive list and a representative list. In your description of your business partners' technologies, you may want to explain that cookies, mobile advertising identifiers, pixel tags, or statistical identifiers may be used.
That the data may be used to deliver interest-based ads to consumers' browsers or devices
That the data may be transferred to one or more third-parties for advertising purposes
2. Provide consumers with information about their choices You should provide consumers with clear information about exercising choice over data collection and use. This could include:
Direct consumers to http://www.aboutads.info/consumers (or equivalent) for more information about interest-based advertising.
Provide consumers with directions to an opt-out mechanism such as http://www.networkadvertising.org/choices.
Provide consumers with instructions for how to contact you with questions or concerns about data collection, privacy, and related issues.
Resources:
Here are some other references that may be helpful in drafting a privacy policy
You may find it helpful to include an opt-out section with links to