Privacy Policy


This privacy policy ("Policy") describes RaMillion, Inc.'s ("RaMillion") provision of a technology and advertising platform for marketers and content publishers such as web sites or email newsletters and operators (together, referred to as "Publishers" or "Publisher Properties") to attempt to deliver more relevant advertisements to consumers. RaMillion does not collect, obtain or maintain personally identifiable information ("PII") from Publishers who use our CustomAd™ technology product. The data collected and maintained by RaMillion from Publishers using CustomAd™ technology ("Anonymous Information") is not sufficient to permit someone to identify a particular consumer by name, email address, mailing address, telephone number or through social security number, driver's license or other government issued ID. This Policy does not apply to the practices of Publishers or other companies that RaMillion does not own or control or to people that RaMillion does not employ or manage. RaMillion retains its rights to enter into new or different lines of business with consumers and if and to the extent it does so, it may display a different Privacy Policy to the consumer for such lines of business.

RaMillion Collection of Information.

Information Collection 1.1 User Information.

User Information. RaMillion does not track or maintain PII about consumers. It maintains Anonymous Information including behavior data (i.e., visiting a particular website or clicking on a particular ad) and demographic or similar data (i.e., browser type or lifestyle data). RaMillion may maintain PII information if it is in an encrypted format which cannot be decrypted; that is, the data as stored is Anonymous Information rather than PII. For example, a Publisher may encrypt the email address [email protected] into the term "123abc" with a one-way encryption routine and transfer the term "123abc" to RaMillion to store on RaMillion's computers, but it is not currently feasible for RaMillion or others, due to the sophistication of the encryption routines utilized, to decode the term "123abc" back into the original email address,[email protected]

1.2 User Behaviors Collected with Cookies, Web beacons, and Other Information.

RaMillion may use cookies, web beacons and IP addresses to associate your Anonymous Information (as described in Section 1.1 above) with an anonymous profile containing data such as your online behaviors, which could include records on viewing, opening or clicking on a particular online advertisement or visiting a website operated by a Publisher. Additionally, RaMillion may use other new and evolving sources of information and information gathering in the future (together, "Technology Information") to assist Publishers in delivering more relevant advertisements to you. Cookies. A cookie is a small amount of data stored on the hard drive of your computer that allows RaMillion to identify your IP address with corresponding information in RaMillion's database. RaMillion may use cookies to track individual responses or views of advertisements when an advertisement has been viewed on Publisher Properties. You may read more about cookies at

Web Beacons

A web beacon is programming code used to display an image on a web page and can assist RaMillion in associating an individual's Anonymous Information to a unique profile in our database. Web beacons enable RaMillion to track certain Web sites you visit or advertisements you view online at Publisher Properties. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes. More information about web beacons is available at

IP Addresses

RaMillion may use your IP address to better target an ad to you or people in your area. Unless you use a static IP address, an IP address relates to households or larger communities. For example, if you use a national Internet Service Provider (ISP) to access the Internet, such as America Online, it may not be possible to determine your geographic location based on your IP address. If you use a local ISP, it may be possible to narrow your community to a fewer number of people or businesses which your ISP services. Because an individual does not own a particular IP address, a consumer's IP address is not personally identifiable information and may change for any number of reasons over time, e.g., even if you rent a static IP address for a limited period.

Where Technology Information is Collected

Technology Information is collected directly from RaMillion advertisements or indirectly through Publishers that RaMillion contracts with to display advertisements. Such advertisements will usually be displayed within one of the following advertising vehicles: Websites. RaMillion may set a cookie on your computer or associate behavior with your Internet service provider's IP address when you view advertisements delivered on Publisher websites. After a behavior is associated to a cookie or an IP address, RaMillion may track how you interact with the advertisement and the Publisher website (for example, registering, purchasing, browsing, etc.).


RaMillion may track your interaction with emails sent to you on behalf of Publishers (for example, when you open or click on an email, register, purchase, or browse in response to such email), but does not maintain a list of email addresses or other PII in connection with this activity.

1.3 Outside Information.

RaMillion may lawfully receive information about you, including demographic data, purchasing trends and similar information, from third parties, such as information located in public databases ("Outside Information"). Outside Information shall be Anonymous Information.

1.4 No Information Collected from Minors

MINORS UNDER THE AGE OF 18 SHOULD NOT PROVIDE ANY PERSONAL INFORMATION, INCLUDING THEIR EMAIL ADDRESS, TO RaMillion. If RaMillion is notified it has any information about a minor under the age of 18, that information will be promptly deleted from our active database.

Use of Information and User Data

2.1 Discretion to Use Information

RaMillion may share Anonymous Information about your behaviors with trusted Publishers under confidentiality agreements. These Publishers may use this information to better target advertisements to you. If you wish to end your email subscription with a Publisher, you may follow the instructions at the end of each email message to unsubscribe or follow the instructions detailed at Section 4 below.

2.2 Targeted Advertising Delivered by Publishers

RaMillion uses Anonymous Information to assist its Publishes in targeting advertisements more effectively. When a consumer is online, RaMillion uses Technology Information to associate an individual with their Anonymous Information and RaMillion assists its Publishers in attempting to show information and advertising for products and services to which the consumer may respond. RaMillion may use data collected from a response to one type of advertising or information for targeting advertisements or other information through a different venue. For example, RaMillion may inform an email Publisher that a consumer responded to a baseball banner advertisement and that Publisher may try to deliver to the consumer a baseball-related advertisement and other information to the consumer via email.

2.3 Legal Process

RaMillion may disclose information in its possession and control to respond to subpoenas, court orders and other legal process as required by law.

2.4 Summary Data

RaMillion may sell or transfer Anonymous Information, such as summary or aggregated non-PII about consumers or consumer sub-groups.

2.5 Storage and Protection of Information

RaMillion stores Anonymous Information in a database on RaMillion computers. These computers have security measures, such as a firewall, to protect against the loss, misuse, and alteration of the information under RaMillion's control. RaMillion also maintains physical and procedural safeguards to protect information. Furthermore, RaMillion maintains the data in its database in encrypted form, so that even if the data is improperly accessed, it is less likely to be in a format intelligible or useable for purposes not authorized or intended by RaMillion. Notwithstanding such measures, RaMillion cannot guarantee that its security or privacy protection measures will prevent its computers from being illegally accessed and the data on them stolen or altered.

Privacy Practices of Third Parties

3.1 Advertiser cookies and web beacons

Publishers who place advertisements on the Internet may use their own cookies, web beacons and other technology to collect information about you. RaMillion does not control Publishers' use of such technology.

3.2 Links

The Publishers' Websites and email messages transmitted on behalf of Publishers may contain hypertext links to the Websites of third parties. RaMillion is not responsible for the privacy practices or the content of such other Websites.

3.3 Publishers

To learn about how a particular Publisher may use your PII or Anonymous Information, you should read the privacy policy of that Publisher.

How You May Exercise Your Privacy Rights And Unsubscribe


To prevent the display of Publisher or RaMillion advertising on a Website, for example, banner advertisements, do not visit the Website. To only prevent RaMillion from tracking your behavior on a Website, turn off cookies, utilize a changing IP address, and do not click on or interact with any advertisements.

Email Databases

To unsubscribe from Publisher email lists, click the link included in the footer of any message you receive from the Publisher.

Please read the privacy policy of particular Publishers to understand how your PII and Anonymous Information may be used after you unsubscribe.