1. Introduction
Impact Radius, Inc. (a California company, with a place of business at 223 East De La Guerra Street, Santa Barbara CA 93101) (“Impact Radius,” “we,” “us” or “our”), operates and uses the website at (the “Website”) to offer access to an advertising tracking platform (the “Platform”) related to online and offline performance advertising.

2. Who may use our Website?
Although certain areas of the Website can be accessed by visitors generally, access to our Platform is not provided to the general public. Only persons or entities that are eligible to enter into further agreement(s) with us may access non-public areas of our website (our “Advertisers” and “Media Partners”). All such Advertisers and Media Partners must be corporations or other legal entities or adults (at least of the legal age to be able to enter into contracts in the jurisdiction in which they reside). Further, Impact Radius reserves the right at its absolute discretion to refuse to provide access to the Platform to anyone for any or no reason.

3. Who uses personal data?
We do not gather information about or from visitors to or users of the public areas of our website solely as a result of such visits or usage. We only gather such information from Advertisers and Media Partners whom we engage in a business relationship and who enter into a user agreement with us. Accordingly, not all of this Privacy Policy applies to all visitors to this website. With respect to each of our Advertisers and Media Partners’ privacy policies, and any non-related site that is linked to from within our website, please contact the owner or operator of each such site directly for their privacy policies.

4. Scope and Effective Date
This Privacy Policy is effective as of March 1, 2010 and covers how and for what purposes personal data is collected by Impact Radius.

Periodically, we may alter our Privacy Policy to better reflect industry changes and/or changes in data protection and privacy law. If our Privacy Policy and/or data protection practices change at some time in the future we will post the policy changes to our website to notify you of these changes. If you are concerned about how your personal data is used, you should check our website.

5. No Personal Data of General Visitors Collected at or by This Site
This site neither requires general visitors to this website to submit personal data, nor does this website collect personal data about general visitors that the visitors do not voluntarily submit themselves. If you do not log into our website, purchase services at our website, or submit the Contact Us form on our website, our web server does not have access to personal data about you. We do not know your email address unless you volunteer it.

6. Collection and Use of Non-Personal Data

(a) Passive Browser Information

Passive Browser information is collected by the web server hosting the Website. This server logs standard information communicated by web browsers as they make requests to the server, including:

IP address of the requesting computer
Date and time of the request
The URL of the actual request
Any cookie returned by the browser
Your browser offers options on the management and preference of cookies that you may change if you wish. Cookies are discussed in this Privacy Policy in more detail below.

(b) Collection of Personal Data: For, site visitors who submit request forms, make purchases, or otherwise log on to our Website, and Advertisers and Media Partners

When you submit the form on the Contact Us section of our Website or make a purchase, the information we collect about you may include your name, company name, contact information, profile and preference information.

This contact information (whether or not including personal data) may be used by us to:

(i) verify your identity;
(ii) administer and support your interaction with our website;
(iii) deliver you with access to our Platform;
(iv) contact you again about other services and products we offer and information on upcoming Impact Radius events;
(v) carry out marketing analysis and make general improvements to our Website and the Platform.

We may outsource some of these activities to our business partners. To the extent we do, we shall use our reasonable efforts to ensure that our business partners will only process your personal data on terms similar to those set out in this Privacy Policy.

We reserve the right to retain and use your contact information as long as we deem necessary to communicate with you and preserve or disclose your contact information as reasonably necessary to comply with our contractual obligations to you and applicable privacy and/or data protection legislation.

If in the future you decide that you do not want us to contact you regarding other services and products we offer or information regarding upcoming Impact Radius events, please opt-out by letting us know in writing by email to

(c) Collection and use of email addresses
We collect the email addresses of those who communicate with us by email. Generally, the email addresses we collect are used to contact existing or potential business customers for the purpose of providing services, information and assistance. We may use the email address to contact existing or potential business customers to introduce new products or services, provide notification of website changes, or provide general business information. If you contact us through the Contact Us form, we reserve the right to retain and use the email address and contact information as long as we deem necessary to communicate with you and preserve or disclose your information as reasonably necessary to comply with our contractual obligations to you and applicable privacy and/or data protection legislation.

If in the future you decide that you do not want us to email you regarding new products or services, provide notification of website changes, or provide general business information, please opt-out by letting us know in writing by email to

7. Cookies
(a) All visitors
“Cookies” are small text files that contain a string of alpha-numeric characters and are used to associate an action taken by a browser with subsequent actions taken by that browser. Web beacons are small strings of HTML code that are placed in a Web page, and are sometimes called “clear GIFs” (Graphics Interchange Format) or “pixel tags.” Web beacons are most often used in conjunction with cookies.

We place unique identifier cookies on the hard drives of those who sign on which are used to maintain the visitor “sign on” status for the duration of the visit, for one-time customizing/tailoring of your visit and for long-term storage of user preferences. We also use cookies to track the pages visited by a visitor so that we can deliver Impact Radius web content based on the visitor’s profile (as provided by the visitor) and the visitor’s past activity on the Impact Radius website.

You can remove cookies by following directions provided in your Internet browser’s “help” file. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust. Cookies from Impact Radius may be stored under one or more of the following domains:,, and/or

(b) Minors
Impact Radius does not knowingly collect any personal information about individuals under eighteen (18) years of age. If Impact Radius obtains actual knowledge that it has collected personal data about an individual under eighteen (18) years of age, that personal data will be immediately deleted from its database.

8. Security
We have implemented security measures that are amongst the industry’s highest in order to protect our users’ personal data, business data and financial information (“Sensitive Information”) from loss, misuse and unauthorized access, disclosure, alteration or destruction. Users may be general website visitors, Advertisers or Media Partners.

When users submit Sensitive Information on the Website, their Sensitive Information is protected both online and offline. When our registration process asks users to submit Sensitive Information and when we transmit such Sensitive Information, that Sensitive Information is encrypted and protected with SSL encryption software. While we use SSL encryption to protect Sensitive Information online, we protect all other user information online and offline.

The servers that we store Sensitive Information in are kept in a secure physical environment. We have security measures in place to protect the loss, misuse and alteration of Sensitive Information under our control. Our employees are made aware of, and are accountable for compliance with, these procedures. With the exception of our technology security experts, no employee has access to back-end systems that would enable them to use (or misuse) your Sensitive Information.

We ensure that strict procedures are followed and documented when back-end systems are accessed by our technology security experts.

Please be advised that, although we take every reasonable precaution available to protect your Sensitive Information, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot warrant that your Sensitive Information will be absolutely secure. Any transmission of data at or through our Website is undertaken at your own risk. However, access to your Sensitive Information is strictly limited, and not accessible to the public. In compliance with applicable data protection legislation, we shall notify you and any applicable regulatory agencies (including the Information Commissioner) if we learn of an information security breach with respect to your Sensitive Information. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

9. Information Sharing and Disclosure
Impact Radius does not rent, sell, or share personal data about you with other people or non-affiliated companies, except under the following circumstances:

in order to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
when it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person; violations of Impact Radius’ terms of use, any agreement with Impact Radius or this Privacy Policy; or as otherwise required by law.
where Impact Radius determines, in its sole discretion, that such disclosure is necessary to protect the rights of Impact Radius and/or a third party, or necessary to protect Impact Radius from liability of any kind.
if Impact Radius sells any or all of its assets or their shareholders sell any or all of their shares to a third party in which case and subject always to compliance with applicable data protection legislation, your personal data may be transferred to the buyer.
10. Changes to your details
We aim to keep our information about you as accurate as possible. If you would like to review or change the details you have supplied to us, please contact our Data Protection Compliance Officer whose contact details are set out above.

11. 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 treat the information collected at this Website, we will post a clear and conspicuous notice of these changes on this Website and in this Privacy Policy.

12. More Information
If you have further questions or concerns relating to this Website’s privacy practices, please email