1. Engage, Inc.

• Who is Engage, Inc.?
• What is Engage Knowledge?

• How does Engage Knowledge protect my privacy?
• How does Engage Knowledge benefit me?
• How does Engage Knowledge work?
• How does Engage Knowledge remember me?
• How does Engage Knowledge ensure my anonymity?
• What information does Engage Knowledge maintain?

• Doesn't my browser tell the web server who I am?
• I have a static IP address. Can't Engage use it to determine who I am?
• I gave my name and address to a web site who participates in Engage Knowledge. Doesn't that eliminate my anonymity?
• Can't Engage combine my anonymous data with identifiable data?
• Can't a sufficient quantity of anonymous data (e.g. birth date combined with zip code) uniquely identify an individual?

• Does Engage Knowledge know what pages I have requested?
• How can I tell whether I am in Engage Knowledge?
• How can I tell whether a site participates in Engage Knowledge?
• Can law enforcement find out who I am from the Engage Knowledge database?
• How do I know that Engage is adhering to its privacy policies?
• What does an Engage Knowledge profile look like?
• Does Engage Knowledge contain information about sexual orientation or medical information?
• How do participating sites use Engage Knowledge?
• How are participating sites prevented from violating my privacy?

• How is Engage working to create a safe privacy infrastructure for the web?
• What are Trust Labels?
• What is P3P?

• How do I opt out of Engage Knowledge?
• Why can't I view or edit my own profile?
• Why can't I opt out of Engage Knowledge by telephone or email?
• Why do I get a new cookie when I opt out?

Return to top

1. Engage, Inc.

1.1 Who is Engage, Inc.?

Engage, Inc. develops and markets precision online marketing solutions that facilitate anonymous profile-based targeting and delivery. Engage is a leader in the field of collecting and using information in a manner that respects and protects user privacy. Corporations use our technology to increase the relevance of their Web site's advertising, editorial and commercial content. Engage delivers both web-wide and enterprise-specific profiling of visitor interests and preferences without tracking their identity, allowing web sites to deliver the best message to the right audience, while protecting individual privacy.

Engage Knowledge is the industry's largest database of behavioral profiles of anonymous web site visitors. Click stream logs and anonymous registration demographics are collected from participating sites across the web and processed by Engage into behavioral profiles. Any personally identifiable information such as name, address, e-mail address, phone number, social security number etc. is not collected. These profiles are accessed in real-time by Engage Knowledge subscribers to personalize Web pages, target ads, promotions, products and services.

Return to top

2. Engage Knowledge and Privacy

2.1 How does Engage Knowledge protect my privacy?

Engage Knowledge protects the privacy of web site visitors through anonymity. Web marketers do not need to know the personally identifiable information like name, address or e-mail address of a web site visitor. Instead, a web marketer only needs the ability to distinguish one web site visitor from another and to recognize that visitor when they return to a site. By restricting the storage and access to the data collected, Engage prevents inappropriate use of the anonymous information and its association with personally identifiable information.

Engage Knowledge helps publishers and advertisers understand the general interests and preferences of their audience. This knowledge is used to personalize their content and offer advertising more relevant to a visitor's interests. For example, a person with an interest in European travel and cruises might get an advertisement for a special on Mediterranean cruises -- increasing the value of the ad to both the consumer and advertiser.

Engage Knowledge is a central repository of anonymous user profiles gathered from participating sites across the web. These profiles are accessed in real-time by Engage Knowledge subscribers to personalize web pages, target ads, promotions, products and services. Web sites do not retain profile information - they can only use it for a single session.

Engage Knowledge uses cookies to assign each visitor a unique identifier on the first visit to that web site. Each visitor has a different identifier for each web site and one for Engage Knowledge. Only Engage maintains a secure cross-reference of these identifiers. This technique is called "dual-blind" identification because the individual web site never has access to the Engage Knowledge identifier or the cross-reference information and Engage does not have access to an individual's identity behind the browser. This means that the web site can't correlate its information with other web sites or even determine what other web sites the visitor has seen.

Engage Knowledge does not capture or store personally identifiable information like name, address, email address, telephone number, social security number, etc. There are no fields in the database for storing this information.

Engage maintains profiles of visitor's interests in categories like baseball, foreign stocks, minivans, and demographics like age range, geographic location, or gender. Information like browser version, operating system, and organizational type and size may also be maintained.

Return to top

3. Anonymity

3.1 Doesn't my browser tell the web server who I am?

Most browsers (including all versions of Netscape after version 0.9 and Internet Explorer) do not inherently transmit identifiable information. The page request immediately following filling out certain forms that contain personally identifiable information may contain that personal information in a field that remembers the previous page request. In addition, if you enter a site that requires username and password, that username and password may be automatically transmitted to the web site. Any such data that is inadvertently gathered by Engage is discarded. No such data is ever added to the Engage Knowledge database.

Engage does not store your IP address or use IP address to store the specific domain name of a web site visitor. Your IP address may be used to determine your organization type and size or your general geographic location. Engage does not store the specific organization name associated with an IP address.

Engage's patent-pending dual-blind identification separates information that the web site collects from the Engage Knowledge anonymous profiles. Engage does not have access to the personally identifiable information at the web site and the web site only has access to the Engage Knowledge anonymous profiles during the duration of the user's visit for the purpose of tailoring the content and advertisements.

Engage does not store identifiable data, and therefore cannot merge Engage Knowledge information with your identifiable information. Any identifiable data that is inadvertently collected is discarded.

Engage specifically avoids the collection of information at a level of detail that facilitates unambiguous determination of an individual's identity. For example, Engage does not store date of birth, but instead stores approximate age or age range.

Return to top

4. Engage Knowledge Profiles

4.1 Does Engage Knowledge know what pages I have requested?

Engage Knowledge looks at pages viewed to infer the interests of the user, but then discards the records of the specific pages viewed.

Currently the only way to verify inclusion in Engage Knowledge database is to locate an Engage Knowledge entry in your browsers cookie file. You should see a cookie entry with a "CyberGlobalAnonymous" label.

Engage requires participating sites to post a privacy statement disclosing the collection and use of visitor data, including disclosure of participation in Engage Knowledge, and including a reference to Engage's privacy statement on www.engage.com.

No. It is impossible to reverse match a profile to a person's identity since no identities are collected.

Engage, Inc. is a corporate sponsor of TRUSTe, an independent, non-profit, privacy initiative. TRUSTe has implemented a comprehensive assurance process made up of initial and periodic Web site reviews, "seeding", conformance reviews, online community monitoring, and enforcement. PricewaterhouseCoopers L.L.P. and KPMG Peat Marwick L.L.P. are the official "auditing" firms for TRUSTe. They perform on-site conformance reviews to check for consistency and adherence to program principles. For more information, select the TRUSTe Trustmark on Engage's web site, or visit www.truste.org.

Engage is also a founding member of the Network Advertising Initiative. As a member of the NAI, Engage required to conform to the principle of the organization. For more information on the NAI, visit (Add NAI link).

A profile record contains an anonymous identifier (e.g. CTL000A77B08F580511258) followed by a string of hierarchical interest codes and interest scores, which measure degree of interest in the category. For example TRAVEL.DESTINATIONS.ALASKA .68 (where .68 is the interest score based on a scale from 0 to 1).

No. Engage Knowledge does not have profile classifications for sensitive subject matter including sexual, medical illness, or racial references.

Web sites and their service providers can purchase from Engage "recommendations" that guide sites in serving relevant content to visitors. Engage generates these recommendations using the profiles internally and does not transmit profiles to third parties.

Engage requires each customer to post a privacy statement disclosing their collection and use of visitor data including a reference to either Engage's privacy statement on www.engage.com or the privacy statement of an Engage network customer (which, in turn, provides access to the Engage privacy policy). Participating sites are prohibited from retaining and storing profile information, combining it with other information, using it to infer identities, or exchange it with third parties.

Return to top

5. Engage's Industry Privacy Activities

5.1 How is Engage working to create a safe privacy infrastructure for the web?

Engage, Inc.' commitment to individual privacy is evidenced through our active membership and participation in organizations such as TRUSTe, the Privacy Leadership Initiative, the NAI, the Online Privacy Alliance (OPA) and other Web standards-setting organizations focused on the maintenance and preservation of information privacy. Engage is a participant in the Platform for Privacy Project (P3P) at the World Wide Web Consortium (W3C) and a co-author of the P3P Protocol Specification. In addition, Engage is the author of an Internet Draft submitted to the Internet Engineering Task Force (IETF) that allows web servers to inform users of their privacy practices with regard to HTTP cookies.

Trust Labels are an implementation of the P3P specification into browser cookies. The proposal recommends that Web sites use "Trust Labels" to associate their Internet privacy practices with information exchanged through cookies. TrustLabels conform to the Platform for Internet Content Selection (PICS) standard, and tell visitors how a Web site will use information stored in a cookie or derived from a cookie. Users will have the ability to accept or reject the site's data practices.

The Platform for Privacy Preference (P3P) is a project of the World Wide Web Consortium (W3C). P3P is a specification that would enable web browsers and servers to negotiate an agreement between a site's information practices and users' privacy requirements. The web server can automatically communicate how it collects and shares user data and the users can define what privacy standards they prefer for that particular site or in general. Sites with practices that meet a user's preferences could be accessed without intervention. Otherwise users will be notified of a site's practices and will have the opportunity to control what data is collected and/or shared.

Return to top

6. Opt Out

6.1 How do I opt out of Engage Knowledge?

Engage provides an easy way for users to opt out of Engage Knowledge. By visiting Engage's privacy statement at www.engage.com/privacy/privacy.htm/ users can run an "opt out" program that eliminates their anonymous identity within the system.

At this time there is no way for Individuals to view or edit their own profile because there is no association between an individual and a profile.

You have no "personal" identity in the system (such as name, address, phone number, e-mail address etc.) and therefore we cannot remove you based on your input from a phone call or e-mail.

Engage Knowledge distinguishes unique users through anonymous identifiers in browser cookies. It is therefore necessary to serve an "opt out" cookie to inform Engage Knowledge that the user associated with the cookie does not wish to be included in the system.

Return to top