Digital Impact, Inc.
177 Bovet Road, Suite 200
San Mateo, CA 94402
Email: privacy@digitalimpact.com

Internet user privacy is of paramount importance to Digital Impact and our clients. We support the protection of client and consumers' privacy rights as a fundamental element of our business.

This privacy policy discloses the privacy practices for Digital Impact, Inc., related to services provided to our clients. For information related to Digital Impact’s data collection practices on our corporate website, please refer to the website’s privacy policy.

Digital Impact works with the world's leading marketers to create permission-based email marketing programs that achieve superior results. Digital Impact is a third party vendor that provides solutions that enable corporations to create and deliver highly successful email marketing programs that drive revenue and deepen customer relationships.

Digital Impact's role in supporting our clients may include delivery of email, hosting the actual subscription collection site, tracking results of email campaigns, analysis of data, and transferring collected data back to the client. These services are provided using a combination of web-based applications, hosted technology infrastructure and professional services.

Respect for customer privacy is the core value of permission-based marketing. Far from limiting the marketer's options, the boundaries of privacy establish a space of opportunity, if obeyed. Messages that remain in accord with these boundaries will frequently find receptive customers. Digital Impact's P3P privacy policy is designed to ensure that users understand how and why Digital Impact may collect and use information.

We support the Fair Information Practice Principles of Notice, Choice, Access, and Security. The following document thoroughly explains our privacy policy related to services we provide to our clients. Please read it carefully. Users may direct questions to Digital Impact’s privacy department at privacy@digitalimpact.com.

WHO WE ARE
Digital Impact is the premier provider of online direct marketing solutions for enterprises. Digital Impact is a third party vendor that provides solutions that enable corporations to create and deliver highly successful email marketing programs that drive revenue and deepen customer relationships. Digital Impact solutions provide deep customer insight and powerful campaign execution through a combination of web-based applications, hosted technology infrastructure and professional services.

These services include the collection and management of customer information. Customers provide this information in two ways: by what they say and by what they do. Digital Impact helps clients collect and manage customer information from a variety of online and offline sources in a securely hosted database, including customer-provided profile data from surveys and registration forms, plus behavioral data such as click and purchase history. This technology enables Digital Impact and our clients to deliver permission-based, individualized messages to customers.

Digital Impact is a third party that processes data only on behalf of our clients for the completion of stated purposes. The client, not Digital Impact, owns data collected by Digital Impact on behalf of the client. Digital Impact is contractually bound to keep clients' customer data private and this data is never shared among clients.

DISPUTE RESOLUTION--QUESTIONS REGARDING THIS STATEMENT
Users who feel that Digital Impact is not abiding by the posted privacy policy should first contact Digital Impact's privacy manager for customer service by email at privacy@digitalimpact.com. Digital Impact will correct any errors in this privacy policy.

For issues related to the corporate website and the privacy policy posted on the Digital Impact website, a user who does not receive acknowledgment of an inquiry or is not satisfied by the response to an inquiry should then contact TRUSTe at www.truste.org. TRUSTe will then serve as a liaison to Digital Impact to resolve the user’s concerns.

For all other issues covered under this statement, users who do not receive acknowledgment of an inquiry or are not satisfied by the response to an inquiry should then contact the Direct Marketing Association (DMA) Ethics Department at ethics@the-dma.org. The DMA will then serve as a liaison to Digital Impact to resolve concerns.

INFORMATION COLLECTION AND USE
Digital Impact collects information for a client from the emails sent on behalf of the client to its customers. At a client’s request, Digital Impact may also collect information for a client from its website.

In addition to sending sophisticated email campaigns on behalf of clients, Digital Impact also provides web page-hosting services and a website tracking and analysis service. Some clients use all of our services. Some clients only use our technology to send email campaigns.

Providing these services, Digital Impact acts as a service provider for our clients. This means that Digital Impact is a third party that processes data only on behalf of our clients for the completion of stated purposes. The client, not Digital Impact, owns data collected by Digital Impact on behalf of the client. Digital Impact is contractually bound to keep clients' customer data private and this data is never shared among clients. Below are detailed descriptions of what information is collected and how this information is used. For information on the collection technology, please see the section below on how this information is collected.

What kind of information does Digital Impact collect on client websites?
For some clients, Digital Impact hosts data collection pages. These data collection pages may include surveys, sweepstakes entries or profile pages, where a user knowingly provides data such as name, email address, physical address, and product preferences. These data collection pages will usually appear to the user as a page that resides on the client website. If the client uses a Digital Impact-hosted data collection page, the client website links to a page that resides on a different server. However, the information is still owned by the client.

Information such as information about the computer system and clickstream data are automatically collected and logged when the user browsers the site, but the data is not personally identifiable. Personally identifiable information provided by the user, such as physical contact information, is optional.

Depending upon the client, Digital Impact may collect the following information from users on subscription management pages (sometimes called “preference pages”), survey pages, sweepstakes pages or similar data collection pages:

• Information that allows an individual to be contacted or located in the physical world -- such as telephone number or address.
• Information that allows an individual to be contacted or located on the Internet -- such as email.
• Unique identifiers issued by a website or service for the purpose of identifying an individual over time, such as username.
• Information about the computer system that the individual is using to access the network -- such as the IP number, domain name, browser type or operating system.
• Information generated by browsing the website, such as which pages on the website are visited.
• Information generated from or reflecting explicit interactions with the website, such as logs of account activity or profile updates.
• Data about an individual's characteristics -- such as gender, age, and income.
• Information that allows users to log on and access secure areas of the web site. This information may be gathered using per-session cookies, which are destroyed when the user closes their browser.
• Data about their individual likes and dislikes -- such as favorite color or musical tastes.

Digital Impact is a service provider and provides clients with a website tracking and analysis service. This service uses cookies to measure the effectiveness of a client's marketing campaigns. On behalf of the client, Digital Impact may collect:

• Unique identifiers issued by a website or service for the purpose of identifying an individual over time.
• Information generated by the purchase of a product or service.
• Information about the computer system that the individual is using to access the Internet, such as the IP number, domain name, browser type, or operating system.
• Information generated by browsing the website, such as which pages on the website are visited.
• Information generated from or reflecting explicit interactions with the website, such as logs of account activity.

Why is this information collected?
The profile data as well as tracking and analysis information are gathered to facilitate a client’s ability to provide relevant offers to customers and determine the effectiveness of marketing campaigns.

Under most circumstances, the user has knowingly provided the personally identifiable information to the client website. For more information on the information collection practices of a client, users may refer to the privacy policy for the client website where the information was submitted.

Following are descriptions of the purposes for the information collected by Digital Impact on profile and other data collection pages hosted by Digital Impact for clients:

• Information may be used to complete the activity for which it was provided, whether a one-time activity such as returning the results from a Web search, forwarding an email message, or placing an order; or a recurring activity such as providing a subscription service, or allowing access to an online address book or electronic wallet.
• Information may be used for the technical support of the Web site and its computer system.
• Information may be used to enhance, evaluate, or otherwise review the site, service, product, or market.
• Information may be used to tailor or modify content or design of the site where the information is used only for a single visit to the site and not used for any kind of future customization. For example, an online store that suggests other items a visitor may wish to purchase based on the items he has already placed in his shopping basket.
• Information may be used to determine the habits, interests, or other characteristics of individuals and combined with identified data for the purpose of research, analysis and reporting. For example, an online Web site for a physical store may wish to analyze how online shoppers make offline purchases.
• Information tied to a pseudonymous identifier but that will not be linked to an individual may be used to determine the habits, interests, or other characteristics of individuals for the purpose of research, analysis and reporting, but it will not be used to attempt to identify specific individuals. For example, a marketer may wish to understand the interests of visitors to different portions of a Web site.
• Information may be used to contact the individual, through a communications channel other than voice telephone, for the promotion of a product or service.
• Information may be used to contact the individual via a voice telephone call for promotion of a product or service.

Digital Impact may gather tracking and analysis information to better determine the interests of active customers. Following are descriptions of the purposes for the information collected by Digital Impact for tracking and analysis on client websites.

• Information that is based upon a unique identifier but that cannot be linked to an individual may be used for research, analysis and reporting. For example, the number of users within a zip code.
• Information that can be linked to an individual may be used for research, analysis and reporting. For example, data about the types of and price ranges of products an individual has looked at.
• Information that can be linked to an individual may be used to make a decision that directly affects that individual. For example, a client may send an individual who has subscribed to email promotions an offer suggesting items the user may wish to purchase based on items the user has purchased during previous visits to the web site.
• Information may be used to enhance, evaluate, or otherwise review the site, service, product, or market. This does not include personal information used to tailor or modify the content to the specific individual or information used to evaluate, target, profile or contact the individual.
• Information may be used for the technical support of the website and its computer system, such as information used in the course of securing and maintaining the site.

What kind of information does Digital Impact collect on behalf of clients using our email delivery service?
Digital Impact sends permission-based email on behalf of clients to their customers. Digital Impact includes a coded sensor in all of its HTML-based email messages to determine the user’s ability to receive HTML-based email messages. The sensor activates when the email message is opened and flags the email address of the user as one that is capable of receiving HTML-based email messages. The web sensor does not function in a text-only email.

The technology is a web sensor, which is described in detail below, under the section “HOW DO WE COLLECT THIS INFORMATION?”

If a user does receive HTML-based email messages, Digital Impact collects data on the email client utilized by the user and whether the user opens an email. Digital Impact collects this information on behalf of the client who sent the email.

Digital Impact may gather information to determine the success of an email campaign by recording which offer links a user clicks on and which web pages the user visits. Digital Impact may use information collected to analyze click-through rates to various offers delivered in an email campaign, or use the information collected to deliver individualized (“one to one”) email campaigns.

Within the email, Digital Impact may collect the following information:

• Information about the computer system that the individual is using to access the network -- such as the IP number, domain name, browser type or operating system.
• Information generated from or reflecting explicit interactions with the email, such as clicking on URL links.

In addition, many emails sent by Digital Impact on behalf of clients include a link that enables users to forward a copy of the email to a friend. Also known as referral marketing, this application is completely optional for email subscribers (the user). Unless the user opts to forward an email, no additional information is collected.

If a user opts to forward the email, the user is first verified as a valid subscriber to the relevant client’s email marketing program. Digital Impact validates a user by using a member’s unique identifier in conjunction with information already stored at Digital Impact (such as the user’s email address and the IP address of their computer).

Once the user is verified as a valid subscriber, the user may forward the email to one or more unique individual email addresses. The only information the user is required to enter is the user’s friend’s email address. Once the email is sent on behalf of the user to the user’s friend, the email address of the friend is not used to contact the friend again, unless the friend visits the client website and subscribes to receive email from the client.

Digital Impact stores the friend’s email address and maps this email address to the email address of the original user (the “forwarder”), in order to provide any promised incentive or to track complaints.

As part of this program, Digital Impact may collect the following information:

• Information that allows an individual to be contacted or located on the Internet -- such as email address.
• Unique identifiers issued by a website or service for the purpose of identifying an individual over time.
• Information generated from or reflecting explicit interactions with the website, such as logs of account activity.
• User has the option of providing their name and the name of the friend to whom they are forwarding the email.

Why is this information collected?
Digital Impact includes technology within the emails to determine a user’s ability to receive HTML-based email messages and to track which links they click on inside the email. Following are descriptions of the purposes for which Digital Impact collects this information on behalf of our clients:

• Information may be used for the technical support of the Web site and its computer system.
• Information may be used to create or build a record of a particular individual or computer that is tied to a pseudonymous identifier, without tying identified data (such as name, address, phone number, or email address) to the record. For example, a marketer may wish to understand the success of an email campaign by analyzing open counts.
• Information may be used by the service provider to complete the activity for which it was provided, to allow users to go to the correct web page when they click on a link in the email.
• Information may be used to enhance, evaluate, or otherwise review the site, service, product, or market. This does not include personal information used to tailor or modify the content to the specific individual nor information used to evaluate, target, profile or contact the individual.
• Information may be used to create or build a record of a particular individual or computer that is tied to a pseudonymous identifier, without tying identified data to the record. This profile will be used to determine the habits, interests, or other characteristics of individuals to make a decision that directly affects that individual, but it will not be used to attempt to identify specific individuals. For example, a marketer may tailor or modify content displayed to the browser based on pages viewed during previous visits.
• Information may be used to determine the habits, interests, or other characteristics of individuals and combined with identified data for the purpose of research, analysis and reporting. For example, an online Web site for a physical store may wish to analyze how online shoppers make offline purchases.
• Information that can be linked to an individual may be used to make a decision that directly affects that individual. For example, an online store suggests items a visitor may wish to purchase based on items he has purchased during previous visits to the Web site.

For the referral marketing program, Digital Impact collects the information needed to forward the email from the user to the friend. Information is collected:

• To complete the activity for which it was provided, the one-time activity of forwarding an email message.
• To address any future complaints or privacy concerns caused by the forwarding of messages.

HOW DO WE COLLECT THIS INFORMATION?
Use of cookies
Digital Impact collects the information described in the previous sections through the use of various technologies, including one called “cookies.” A cookie is a piece of data stored on the user's hard drive containing information about the user.

For the tracking and analysis services provided on a client website, Digital Impact sets the cookie when a user clicks on a specifically coded link in an email to the user from the client website. The cookie is set every time a user clicks on the coded link. The cookie is read by the client website wherever the website wishes to identify traffic on its website generated by a marketing campaign.

The cookie set is a persistent cookie. “Persistent” means that the cookie remains on the user’s hard drive after the browser is closed. The cookie set by Digital Impact expires 30 days after the last time a user clicks on the coded link in the relevant email.

Simple data collection pages may use per-session only cookies to allow users to log on and access secure areas of the site. These cookies are destroyed when the user closes their browser.

Users can set their browsers to notify them before a cookie is read, giving them the chance to decide whether to accept it. Users can also set their browsers to turn off cookies. However, if they do so, some areas of some sites may not function properly.

Use of web sensors for tracking and analysis
Digital Impact and some clients also use web sensor technology. A number of pages across client websites may have these sensors. When a user accesses these pages, notice of that visit is generated. As described above, this “notice” may or may not be tied to personally identifiable information, depending upon the purpose of the data collection.

If users turn off cookies, web sensor technology will still detect visits to the client website pages where web sensors are located. However, the notices the sensors generate cannot be associated with other cookie information and will be counted in the aggregate.

Web sensors in email messages
In order to determine a user's ability to receive HTML-based email messages, Digital Impact includes a coded sensor in all of its HTML-based email messages. The sensor activates when the email message is opened and flags the email address of the user as one that is capable of receiving HTML-based email messages.

This capability helps Digital Impact to send the e-mail in a format users can read. The sensor does not collect or use any other information. If the user cannot receive HTML, the user will not receive a functioning sensor.

In addition, the sensor provides Digital Impact with information on how many users open an email. This information is used to compile aggregated statistics about an email campaign for our client.

WHO HAS ACCESS TO THIS INFORMATION?
For information collected on client websites, web pages we host for clients and emails sent by us on behalf of clients, the client for whom we are providing the service has access to the data collected. The client owns the information and once the data is transferred (via a secure server) to the client, the client controls who has access to this information.

Prior to this transfer, Digital Impact limits access to the data to employees responsible for receiving, storing and transferring the data to the client. Digital Impact is bound by contract to maintain client data in a secure environment.

HOW LONG IS THE INFORMATION RETAINED?
Digital Impact retains data collected for as long as each client requires it. This time period varies for each client. Web log data may be retained for an indefinite period of time.

DO USERS HAVE ACCESS TO THEIR INFORMATION?
Digital Impact requires that all clients include an unsubscribe link in every marketing email sent to users through Digital Impact’s system. Digital Impact also requires that all clients honor unsubscribe requests in a timely manner. For specific information on how to access information users have provided to a client website, users should consult the privacy policy of the client website where they submitted the information.

Digital Impact only provides the information collected to the client for whom it is collected. Users may have access to certain information collected by the client and should consult the client’s website privacy policy for more specific information.

Digital Impact does not currently provide a mechanism that allows individuals to opt out of the use of information for a particular purpose. However, the user should be able to access profile pages and unsubscribe from email messages at any time. The client may provide users access to this information.

In addition, a user can opt out of an email list managed by Digital Impact by sending an email to postmaster@digitalimpact.com or privacy@digitalimpact.com. Users should indicate the email list from which they would like to be unsubscribed and the email address where they receive the messages.