PrivDog Privacy Policy

Hi

Reference your Privacy Policy for PrivDog ( as it is currently at time of posting on the bottom of the PrivDog website http://www.privdog.com/privacy.html )

I have a few questions / suggestions

This first quote is separated because I find the presentation of it to me as an end user of PrivDog a little confusing as to what applies to me, you begin by distinguishing End Users from Advertisers …
But then begin another paragraph after Cookies and other Technology which if I read it correctly applies to everyone ? ( because you have not distinguished End Users from Advertisers in this case )
And then begin another paragraph “For End Users” which pertains to URLs …

1. Collection of Personal Information

For End Users
No personal information of end users is collected.

For Advertisers/Publishers/User Owners *:
Personal information is collected by AdTrustMedia, LLC in order to establish your account, to handle billing and to understand your specific needs to serve you better. Personal information is information about you that is personally identifiable, such as your name, address, email address, Tax ID or phone number.

Cookies and Other Technology

AdTrustMedia, LLC may use cookies and other technologies to enhance your online experience and to learn about how you use our website and services. A “cookie” is a small file containing a string of characters that uniquely identifies your browser. While most browsers accept cookies by default, you can manually set your browser to refuse all cookies, accept cookies from specific websites, or highlight when a cookie is sent to your browser. AdTrustMedia, LLC’s servers may also automatically record information when you visit our website, including the URL that directed you to our website, your IP address, browser type and the date and time of your visit.

For End Users
If the PrivDog product is installed, then AdTrustMedia, LLC may send the URL ** you are browsing in supported browsers to the servers of AdTrustMedia, LLC to help show you relevant advertisements.

My Bold *
Could you also please define “User Owners” - Because to me as an end user that sounds like you are describing another party who could own me.

My Bold **
By “may send the URL”, I presume you mean that this ‘will’ happen if the site you are looking at is ‘not’ in the Trusted sites exception list, but will not happen if the site is not trusted ( to enable you to feed a clean targetted add in its place back to the user )

2. How AdTrustMedia, LLC Uses Your Information

The information collected is used to comprehensively understand your needs and interests, and permits AdTrustMedia, LLC to deliver a more consistent and personalized experience. For example, AdTrustMedia, LLC may use your information to:

Provide promotional offers and display relevant advertisements.
Your information may be aggregated with other clients’ information on a purely non-identifiable basis to understand how our products are used to help make them better.

  1. I understand is describing that all aggregated data from all PrivDog users could be used to determine trends etc, but nothing personally identifiable is used.
    And I believe this is just pertinent to End Users ?
3. Policy On Sharing Your Information

AdTrustMedia, LLC will not sell, rent or lease your personal information to others *.

Circumstances may arise, whether for strategic or other business reasons, in which AdTrustMedia, LLC decides to sell, buy, merge or otherwise reorganize businesses in various countries. Such a transaction may involve the disclosure of personal information ** to prospective or actual purchasers, or, conversely, the receipt of such personal information from sellers. It is AdTrustMedia, LLC’s established practice to seek appropriate protection for all personal information in advance of any such transaction.

We may have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process or legitimate governmental request, (b) detect, prevent, or otherwise address suspected fraud, security or technical issues, (c ) enforce any applicable Terms of Service, including investigation of potential violations thereof, or (d) protect against imminent harm to the rights, property or safety of AdTrustMedia, LLC its users or the general public as required or permitted by law.

My Bold *
What about giving it away for free ?

My Bold **
This instance of the use of ‘Personal Information’ needs to be better defined for end users reassurance, details of what personal information may be disclosed in those cases.
Or does it apply to End Users ? ( there is no distinction here between End Users and Advertisers / Publishers / User pwners )

4. Sites Covered By This Privacy Policy

The AdTrustMedia, LLC websites (www.adtrustmedia.com and www.privdog.com) may from time-to-time link to third-party websites for your convenience and to provide easy access to additional useful information. Should you select such a link, you will leave the AdTrustMedia, LLC website. AdTrustMedia, LLC does not control those sites nor their privacy practices, which may differ from AdTrustMedia, LLC’s practices and policies. Any personal data you choose to provide to or that is collected by such third parties is not in any way covered by the AdTrustMedia, LLC Privacy Policy. It is recommended that you read over such website’s privacy policy before providing any personal information. A link to another website from AdTrustMedia, LLC websites does not constitute an endorsement or representation about the value, quality or usefulness of anything found on that third-party website.

Understood - Click a link on our website and go somewhere else from our website then we are not responsible thereafter :slight_smile:

a. PrivDog Product (www.privdog.com)

THIS PRODUCT PREVENTS ADVERTISEMENTS FROM DISPLAYING ON THE INTERNET AND WEBSITES YOU VISIT ON THE INTERNET BY STOPPING COMMUNICATION WITH THIRD PARTY ADVERTISING NETWORK SERVERS.

IF YOU DO NOT WISH TO PREVENT THE DISPLAY OF THIRD PARTY ADVERTISEMENTS, DO NOT INSTALL THIS PRODUCT.

THE “TRUSTED ADVERTISEMENTS” FEATURE DISPLAYS ADVERTISEMENTS FROM A TRUSTED SOURCE IN THE EMPTY ADVERTISEMENT SECTIONS OF WEBPAGES WHERE ADVERTISEMENTS ARE PREVENTED FROM DISPLAYING ON THE USER’S COMPUTER BY THE PRODUCT.

THE “TRUSTED ADVERTISEMENTS” FEATURE ALSO OVERLAYS SEARCH RESULTS ADVERTISEMENTS WITH ADVERTISEMENTS FROM A TRUSTED SOURCE IN THE FORM OF AN OVERLAY WINDOW. THIS WINDOW IS IDENTIFIED BY DISCLOSURE OF AN “AT-M Ad’ ON THE TOP LEFT OR RIGHT SECTION OF THE WINDOW. TO VIEW THE OTHER ADVERTISEMENTS UNDERNEATH THE TRUSTED ADVERTISEMENTS OVERLAY WINDOW AND CLOSE THE WINDOW, CLICK THE “See Non AT-M Ad” LINK PRESENT ON THE OVERLAY WINDOW.

IF YOU ELECT TO RECEIVE “TRUSTED ADVERTISEMENTS” WITH THE PRODUCT, YOU ARE GIVING EXPRESS PERMISSION TO ADTRUSTMEDIA TO SEND ADVERTISEMENTS TO YOU SOLEY FROM ADTRUSTMEDIA AND ITS AFFILIATES. THE ADVERTISEMENTS ARE DELIVERED TO YOU USING GEOLOCATION DATA OF YOUR COMPUTER. IF YOU DO NOT WISH TO RECEIVE ADVERTISEMENTS SOLELY FROM ADTRUSTMEDIA AND/OR ITS AFFILIATES, DO NOT SELECT THE “TRUSTED ADVERTISEMENTS” OPTION.

AFTER USING THE “TRUSTED ADVERTISEMENTS” OPTION, IF YOU WISH TO TURN OFF THE “TRUSTED ADVERTISEMENTS” FEATURE, TAKE THE FOLLOWING STEPS:

a. When an advertisement is displayed, there is a disclosure at the bottom right of the advertisement indicated by “AT-M Ad” and an icon.
b. Click on the icon to bring up a menu with the option “Ad preferences.”
c. Click on Ad preferences and it opens a page to select either the “Block all ads” or “Only allow Trusted Ads to be shown” functionality.
d. Click on “Block all ads.”

My Bold “TRUSTED ADVERTISEMENTS” - I do not see anywhere in the PrivDog interface that mentions this …

Does it mean the Exceptions ?, in which case the Privacy policy needs to be using the same terminology …

Or this just may be something I am not seeing because I am unlikely to trust ( put in Exceptions ) any site ( yeah I know, bit of a jaded outlook but we have had so many years of not trusting adverts its going to be hard to shake off even with a good solution to the problem :slight_smile: )

TO UNINSTALL THE PrivDog PRODUCT, TAKE THE FOLLOWING STEPS:

a. Go to “Add or Remove” on your operating system.
b. Select or highlight the PrivDog program, then click “Remove.” *

  1. Access To and Accuracy Of Your Information

For End Users
No information of end users is collected.

For Advertisers/Publishers/User Owners **
We ask that you update your information as and when it changes so any information used to serve you remains as accurate as possible.

  1. Keeping Your Information Secure

To prevent unauthorized access and disclosure, to maintain data accuracy, and to ensure the appropriate use of your information, AdTrustMedia, LLC utilizes industry standard physical, technical and administrative procedures to safeguard any personal information we may collect.

  1. Changes To This Policy

If and when there are future changes to our Privacy Policy, in response we will post them at www.adtrustmedia.com and www.privdog.com.

  1. Contacting Us

My Bold “Remove.” *
Remove = Uninstall ? ( for windows users anyway )

My Bold User Owners **
I really dont like that description :stuck_out_tongue:

Last question - In the ( maybe unlikely ) event that PrivDog and / or AdTrustMedia changes hands with another company in future, would all “personal information” ( currently undefined ) be purged from all servers and the new company would need to start aggregating data from the beginning ?

I am not a lawyer ( IANAL ), just having a stab at this as a user trying to understand what is unusually quite short for a privacy policy ( I hope my questions do not make it grow significantly, that also puts people off reading the ■■■■■■ things :slight_smile: ), and maybe helping to refine it for the benefit of other users reading it.

excellent questions…

all these questions will help us improve our Privacy policy even better.

I will make sure our guys analyse this post.
thank you!

3. Policy On Sharing Your Information

AdTrustMedia, LLC will not sell, rent or lease your personal information to others.


I believe that sdes spelled correctly.

My Bold * What about giving it[u] away for free[/u] ?

How to understand this?
:-\

:slight_smile: Cool, that is the intended purpose of creating the topic

My point in that was that this line …

“AdTrustMedia, LLC will not sell, rent or lease your personal information to others.”

Does not say to the user that …

We will not give personal information away for free

It would be better worded something similar to …

“AdTrustMedia, LLC will not sell, rent, lease or give away your personal information to others.”


When people examine a privacy policy ( not just end users ), especially where money is to be made from advertising, they will carefully scrutinize every word / context / and how it is interpreted by the reader ( be that an end user, or another advertising company … And in particular will look for what is not being said in relation to any particular party.

As I mention at the start of the first topic, the opening part of the whole policy starts by distinguishing end users, but as you read on it becomes less distinguishable as to what parts of the policy specifically apply to just the end user or whether parts apply equally across the board to End Users AND Advertisers/Publishers/User Owners ( whatever “User Owners” are )

It would be better overall I think if all parts relevant to End Users, were in an “End Users Privacy Policy” ( separated from the rest ) …

End Users Privacy policy -------------
  1. Collection of personal information

No personal information is collected about you

Cookies and Other Technology

If the PrivDog product is installed, then AdTrustMedia, LLC may send the URL ** you are browsing in supported browsers to the servers of AdTrustMedia, LLC to help show you relevant advertisements.

  1. How AdTrustMedia uses your information

( insert parts here that only apply to the end users )

etc etc

Advertisers/Publishers/User Owners ( whatever "User Owners" are ) --------------------------------------------------------------------------------------------
  1. Collection of personal information

Cookies and Other Technology

AdTrustMedia, LLC may use cookies and other technologies to enhance your online experience and to learn about how you use our website and services. A “cookie” is a small file containing a string of characters that uniquely identifies your browser. While most browsers accept cookies by default, you can manually set your browser to refuse all cookies, accept cookies from specific websites, or highlight when a cookie is sent to your browser. AdTrustMedia, LLC’s servers may also automatically record information when you visit our website, including the URL that directed you to our website, your IP address, browser type and the date and time of your visit.

  1. How AdTrustMedia uses your information

( insert parts here that only apply to Advertisers/Publishers/User Owners ( whatever “User Owners” are ))

etc etc

I have probably got the above wrong as to how it should go … Because I do not understand how the “parts” of the policy apply to me, its not clear, but you get the idea …

A Privacy policy in two parts,
the first with only relevant information which applies to the End User
( And I think the End User Privacy Policy should be first and prominent )
the second privacy policy with only relevant information which applies to Advertisers/Publishers/User pwners

At the moment with it all being mixed up and confusing, that may put End Users off from even trying it ( which would = less people adopting using it = bad for business )

I do realise that there will be some duplication of relevance in both policies, maybe two links at the bottom of the page … One link for the End User Privacy Policy, and another link for the Advertisers Privacy Policy ( and at the top of that policy page, state that “None of the following applies to End Users” )

And you kind of want to get away from the old image of advertising which is perceived as being obfuscated, and having multiple layers of clauses backed up by legal teams which are indecipherable to the average person who is going to use it and probably means “we can get out of any of this and you would need a lot of money to get nowhere fast trying to reproach us for anything you consider to be bad practice - Just click yes user, we are the borg, standby to be assimilated :)”
^^ A typical example is have you bought a mobile phone recently and read through ALL of its privacy policy before you were allowed to use it ?, where was the “I do not agree” button ?, did the shop assistant even allow you to have time to read 400 pages when they were selling it to you ? … :slight_smile: I think not.

I know there is a lot to consider for a privacy policy ( and after all you are a business so need to cover your ■■■ and not commit financial suicide ), but every effort that can be applied to making the privacy policy as perfect as it can be in all respects ( and importantly the end users perception that you are going to be honorable and not just blind them with jargon ) could be time well spent.
I can imagine your legal team looking at this and thinking “you wish” ( after they pick themselves up off the floor from laughing at the naivety ). But if this technology has the ability to shape the future of the internets economy in a new way, its worth getting right.

Quell the doubt with new approaches to “End Users” aswell as new approaches to software.

Little details like Geolocation are red rag to a bull in a privacy shop these days … It needs to be detailled publicly in the policy ( not just mentioned in passing among a heap of jargon ) that you do not collect / gather End User Geolocation data, but its just used … How ?
Similarly search engine results are mentioned, how are they utilised per end user, any gathering, if the answer is “no” thats a plus point from an end users point of view, but currently we can only guess.

And I must say, this is the first time I have ever witnessed engagement with the great unwashed on such matters as the privacy policy. Very unusual. And appreciated.

Edit: Well thats me finished at having a poke at the policy … Others need to join in, and it is not something that can be word smithed overnight. Bit of a balancing act for this Puppy in a dog-eat-dog world ( okay I’ll stop now :slight_smile: )

"AdTrustMedia, LLC will not sell, rent, lease[u] or give away[/u] your personal information to others."
Clear. So well.

agreed.

Melih you might also want to get them to have a look at the Terms & Conditions page aswell

Have a look at reply #4 in this topic https://forums.comodo.com/help-privdog/sanitized-ads-blocked-t96237.0.html;msg693238#msg693238

And … From my first post in this topic I said …

My Bold "TRUSTED ADVERTISEMENTS" - I do not see anywhere in the PrivDog interface that mentions this ..

Now I know where TRUSTED ADVERTISEMENTS is mentioned, you have put instructions ( documentation ) to use PrivDog, mixed in with Terms & Conditions ( EULA ) http://www.privdog.com/eula.html ← No End Users will look there for PrivDog usage documentation.

Hi w33d3r,

Thank you for your extensive feedback.

I’ll be bringing this to the attention of the appropriate legal teams and we’ll review what needs to be revised.

Shane.