Personally Identifiable Information
Protecting privacy is central to DELFIN?s business policy. DELFIN?s business model is customer centric and as such puts the control of the client experience into the hands of the customer. As such we maintain strict customer information privacy policies and strive to protect customer information and communications from unauthorized intrusions.
DELFIN protects online personally identifiable information as follows:
Disclosure: DELFIN will not sell, trade or disclose to third parties any personally identifiable information derived from use of a DELFIN online service -- including customer names and addresses -- without the consent of the customer (except as described in the Improper Conduct section below). When DELFIN uses agents, contractors or companies to perform services on its behalf, including agents that serve advertisements to DELFIN users and DELFIN Web Site visitors, DELFIN will ensure that the company protects your personally identifiable information derived from the registration for or use of a DELFIN online service consistent with this Policy. If DELFIN includes your name and any other personally identifiable information in a directory that DELFIN creates from information we receive as an online service provider, the company will give you the opportunity to have your information excluded from that directory. Business directories that DELFIN creates may, however, contain information obtained from other sources.
Collection and Use: DELFIN will use personally identifiable information to provide and change service, to anticipate and resolve problems with your service, or to create and inform you of products and services that better meet your needs. This means that DELFIN may use your personally identifiable information (as described in the next section below), in conjunction with information available from other sources, to send advertisements and marketing messages to you that we believe will be of interest to you. In fact, one of the reasons we are able to provide DELFIN services at no cost is by being able to market products and services that are of particular interest to you by targeting messages to you using personally identifiable information along with information obtained from your use of DELFIN Web Sites (including responses to DELFIN generated surveys, questionnaires, contests and sweepstakes), your web surfing habits, and from other sources. However, we will not disclose any of your personally identifiable information to third parties that want to market products to you without your express consent.
How messages will be targeted to you in connection with the DELFIN PromulGate Service: DELFIN will establish a unique anonymous identifier for each DELFIN PromulGate user. DELFIN will provide this identifier and the member?s zip code and/or area code to its advertising agents. DELFIN will also collect certain anonymous information about the members and users of DELFIN services and provide such information to its advertising agents in a manner that may link the anonymous information with the unique anonymous identifier for each member. The advertising agents, subject to their own privacy policies, may also collect anonymous information connected to the unique anonymous identifier for each member including the members? click patterns of web pages presented within the PromulGate service and use such information to improve their ability to send marketing messages. DELFIN and its advertising agents do not collect member?s click pattern for websites selected outside of the PromulGate Service. DELFIN and its advertising agents (not the advertised company) will then use the information described above to send targeted marketing messages (not all marketing messages will be targeted) to DELFIN PromulGate users. The messages may appear in the PromulGate Service ad windows, on the DELFIN Web Site you are visiting, or in email or other direct marketing communications to you. DELFIN will not provide any advertising agent (see the Ad Agents section below for more information) that generates or collects its own information about Internet users and their World Wide Web surfing patterns or any third party (without the customer?s consent) with the information necessary to link a DELFIN generated unique anonymous identifier assigned to that member with the member?s personally identifiable information. Despite DELFIN?s efforts described above, please be aware that DELFIN does not control third party activities or web sites. If you link to a third party web site or respond to a third party advertisement then you, not DELFIN, may be providing personally identifiable information to that third party or its agents. Therefore, we recommend that you review the privacy policies of third party web sites before providing them with your personally identifiable information.
What is anonymous information collected by DELFIN? Anonymous information is information that is not tied to any individual, but helps to characterize DELFIN?s users (for example, the average user prefers movies to game media while logging onto the internet). DELFIN servers automatically gather information about which web pages selected from within the PromulGate Services members visit on the Internet, and which DELFIN Web Site pages are viewed by all visitors. Any web pages selected outside the PromulGate Service by a customer is not tracked by DELFIN. Anonymous information collected by DELFIN includes the domain names of browsers that visit our DELFIN Web Sites, the time of day a DELFIN Web Site was visited, the DELFIN Web Sites visited, and other non-personally identifiable information including a specific country or geographic location of a customer as determined by a customer?s public and non-personally identifiable IP address (See section Use of IP addresses below). We use this information to personalize your experience at our Web Sites, to show you more relevant marketing messages and to improve our services. DELFIN does not share any anonymous information about your use with third parties (without your consent) if that information is or will be linked to your personally identifiable information.
What is anonymous information collected by others? In addition to anonymous information collected by DELFIN from users of DELFIN?s PromulGate Service and visitors to our Web Sites, advertising agents and other web sites you visit may collect anonymous information. The following types of anonymous information about Internet users are often collected by advertising agents (like DoubleClick and 24/7 Media, Inc.):
Customer Choice: A customer may choose not to receive marketing communications from DELFIN by email or telemarketing in connection with DELFIN online services or third party advertisers.
For information and instructions about how to make this choice and to have any information removed from DELFIN?s records and databases please send an e-mail message to: firstname.lastname@example.org
Security: DELFIN has implemented security features and strict policy guidelines to safeguard your personally identifiable information from unauthorized access or improper use, and we will continue to enhance our security procedures as new technology becomes available.
E-mail Contents: DELFIN will not read or disclose to third parties private e-mail communications that are transmitted using DELFIN services except as required to operate the service or as otherwise provided for in the Improper Conduct section below.
Improper Conduct: We may disclose your personally identifiable information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you, or otherwise injuring or interfering with DELFIN?s rights, property or operations, or the rights of other DELFIN users, or others who may be harmed by such activities. We may also disclose your personally identifiable information when we believe the law requires it, or in response to a demand by law enforcement authorities in connection with a criminal investigation, or civil authorities in connection with a pending civil case.
Account Information: DELFIN honors requests from customers for account information, such as name, address, or billing information, and will correct any such information which may be inaccurate. Customers may verify that appropriate corrections have been made.
Application Automatic Update: In order to ensure the PromulGate Service is functioning as error-free as possible, from time-to-time, DELFIN makes updates to the software installed on your system. These updates include new features, new functions, and bug fixes to correct errors. These updates are infrequent (usually not more than once a month) and the size of these updates are relatively small (usually less than 500KB). You as a customer will be given the option of whether or not to install any new feature and any new function when the update is made available.
Changes in Practices: DELFIN will keep this Policy current. The company will inform you of any changes that we make.
Cookies: How they are used and how to accept/decline them
How they are used: A "cookie" is a small piece of data that is sent to your browser from a web server and stored on your computer's hard drive. Cookies do not damage your system or impair its functioning in any way. Cookies may be used by DELFIN, DELFIN?s ad agents and DELFIN?s partners on co-branded Web pages, as explained below in " third party relationships" as well as by other ad agents and third parties so please be aware of this as you visit these web pages.
You can choose whether to accept cookies by changing the settings of your browser. You can reset your browser to refuse all cookies, or allow your browser to show you when a cookie is being sent. If you choose not to accept cookies, your experience at our site and other Web sites may be impaired and some features will not work as intended. This feature enables personalization, e-commerce and Internet advertising in many ways, including:
? Eliminating the need to identify yourself each time you visit a site - it can remember user names and passwords for future visits; ? Enabling personalization features such as stock portfolio tracking and targeted news stories; ? Allowing shopping sessions and quick navigation across multiple zones of e-commerce sites; ? Controlling ad frequency, or the number of times a user sees a given ad; and ? Delivering advertisements targeted to a user's interests. DELFIN?s advertising agents, or other ad agents, may place a cookie on your computer when you first view an advertisement served by the agent (this could happen while you are visiting our site or another site where the ad agent serves ads). This cookie is used by the ad agent to control the sequence of ads displayed to you, to prevent the repetition of the same ad too many times, and to measure the effectiveness of advertisements on behalf of the advertiser. Because the ad agent also serves advertisements for other online companies, the ad agent is able to track ad effectiveness on the web sites of those other online companies through the use of this same cookie. DELFIN does not have the ability to control or remove these cookies. However, if you do not want an ad agent to place cookies on your computer, there is a simple procedure described below that allows you to deny or accept this feature.
Accepting/Declining Cookies: To eliminate cookies you may have currently accepted, and to deny cookies in the future, please follow this procedure:
If you are using Netscape Navigator 3.0, go to the Options Menu, to Network Preferences and then to Protocols. Check the box that says "Show an alert before accepting a cookie." Then go into your Netscape folder (usually c:\program files\netspace\navigator) and delete the file, which is called "cookies.txt." Under Windows 95, you could also use the Find feature on the start menu to simply find the file called Cookies.txt.
If you are using Netscape 4.0+, go to "Edit" in the menu bar, click on "Preferences", click on "Advanced", and check the box that says "Warn me before accepting a cookie". Now go to your "Start" button, click on "Find", click on "Files and Folders", type "cookies.txt" into the search box that appears, and click "Find Now". When the search results appear, drag all files listed, into the "Recycle Bin". Now shut down and restart your Netscape.
In Internet Explorer 4.0, go to the View menu, then to Internet Options, then to Advanced. Check the box that says "Prompt before accepting cookies." Then go into your cookies directory (usually c:\windows\cookies) and delete all the files you have there. Once you delete these files, you will have no more cookies, and you will be prompted each time a Web site attempts to send a cookie to your system.
In Internet Explorer 5.0, go to the Tools menu, then to Internet Options, then to Security and to Custom Level. Once in Custom Level scroll down to the section called Cookies and then check the "Disable" box within the two subsections of the Cookies section. They are "Allow cookies that are stored on your computer" and "Allow per session cookies (not stored)." Then go into your cookies directory (usually c:\windows\cookies) and delete all the files you have there. Once you delete these files, you will have no more cookies. If you have set your browser for "Prompt" instead of "Disable" then you will be prompted each time a Web site attempts to send a cookie to your system. At that time, you can choose to either Accept or Cancel the cookie.
Use of IP Addresses
An Internet protocol (IP) address is a set of numbers that is dynamically generated and automatically assigned to your computer whenever you log on to your Internet service provider, for example, through your company?s local area network (LAN) or wide area network (WAN). Web servers - the powerful computers that provide web pages for viewing - automatically identify your computer by the IP address assigned to it during your session online.
Since DELFIN is not an Internet Service Provider it cannot link a user?s IP address to personally identifiable information of that user, which means that while each user?s session will be logged, the user remains anonymous to us. See also the Improper Conduct section above.
In order to provide you with the best in movies, music videos, games etc., and other products and services that match your interests, DELFIN has relationships with many of the best media and services companies throughout the world. You can recognize these sites by the joint branding of DELFIN and such companies.
Whenever you provide registration information on certain co-branded Web pages or for certain services provided in conjunction with third party partners, some data you provide may be shared with these partners. However, personally identifiable information will not be shared with such third party partners unless otherwise disclosed at the co-branded Web site. You should make every effort to read the privacy policies provided by such third parties, and make an informed decision about whether or not to continue utilizing the services based upon the privacy policies or other privacy disclosure information posted on these co-branded Web pages, at your own discretion. However, we will make every effort to ensure that you have the ability to opt-out of the sharing of such data with such partners.
Additional Privacy Protections for Children Using the Internet
DELFIN joins the industry in recognizing that children, including young teens, may not be able to make informed choices about personal information requested online.
In addition, on all of its online services and DELFIN Web Sites, DELFIN will encourage children to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet.
Finally, DELFIN encourages parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children. DELFIN supports the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households.