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PRIVACY @ ORACLE
ORACLE ADVERTISING PRIVACY POLICY


1. INTRODUCTION

This Oracle Advertising Privacy Policy (also referred to as the ‘Privacy Policy’
or the ‘Oracle Data Cloud Privacy Policy’) informs consumers (‘you’ or ‘your’)
on the collection, use, sharing, and selling (collectively referred to as
‘processing’ or ‘process’) of your personal information in connection with
Oracle’s provision of Oracle Advertising services designed to help Oracle’s
customers’ and partners’ online and offline marketing activities (‘Oracle
Advertising’). This Privacy Policy also explains your privacy rights in relation
to these processing activities.

This Privacy Policy was last updated on September 23, 2022. However, the Privacy
Policy can change over time, for example to comply with legal requirements or to
meet changing business needs. The most up-to-date version can be found on this
website. In case there is an important change that we want to highlight to you,
we will also inform you in another way (for example, via a pop-up notice or
statement of changes on our website). View a previous version of this Privacy
Policy.

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means
information that relates to an identified individual or to an identifiable
individual. For example, this could include among other things your name,
address, email address, past purchase behavior or information regarding your
online interests. Personal information about you that Oracle may process is also
referred to as ‘information about you.’ For more detail about the types of
information about you that Oracle Advertising may process, please refer to
Section 4 below.

SCOPE OF THE PRIVACY POLICY

See
More
 * The Privacy Policy applies to Oracle’s processing of information about you
   that has been provided to Oracle Advertising by our data suppliers.

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?

See
More
 * Oracle Corporation and Oracle America, Inc. are responsible for the
   processing of information about you as described in this privacy policy.

WHICH CATEGORIES OF PERSONAL INFORMATION DO WE PROCESS?

See
More
 * Oracle may process online personal information that may indirectly identify
   you, as well as offline information that may directly identify you.

WHERE DO WE SOURCE YOUR PERSONAL INFORMATION?

See
More
 * Oracle obtains data from third party sources, including from advertising
   agencies, website operators, retail stores, and third party data providers.

WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

See
More
 * We use personal information about you to enable Oracle Advertising customers
   and partners to market products and services to you, to develop and improve
   Oracle products and services, and for security and compliance purposes.

HOW CAN WE SHARE OR SELL YOUR PERSONAL INFORMATION?

See
More
 * Your personal information is shared throughout Oracle’s organization and sold
   or shared to third parties such as Oracle Advertising customers and partners,
   service providers, and others as described in Section 9.

WHAT ARE YOUR PRIVACY RIGHTS?

See
More
 * You have privacy rights for the information we process about you. You can
   request to opt-out of third party sharing or selling, and object to our use
   of your personal information for online behavioral marketing and advertising
   purposes, delete your personal information, or access your personal
   information (See Section 13)

HOW TO CONTACT ORACLE IF YOU HAVE ANY QUESTIONS, COMMENTS OR COMPLAINTS?

See
More
 * If you believe your personal information has been used in a way that is not
   consistent with the Privacy Policy, please contact the Global Data Protection
   Officer at the address below.


2. SCOPE

The Privacy Policy applies to Oracle’s processing of information about you
provided to Oracle Advertising by our third-party data suppliers to help enable
Oracle Advertising customers and partners to market products and services to you
based on your interests.

The Privacy Policy does not apply to the following activities:

 * Data collected in connection with the Oracle AddThis tools. In some regions,
   Oracle may also process information about you provided to Oracle Advertising
   by website publisher partners using the Oracle AddThis tools. For information
   about Oracle’s data collection and use practices in connection with the
   Oracle AddThis tools, please refer to
   https://www.oracle.com/legal/privacy/addthis-privacy-policy.html.
 * First-party information collected about you by Oracle customers. Our
   customers are responsible for their own personal information collection
   practices and their use of the personal information for marketing and other
   purposes, including when they use Oracle Advertising services to send you
   online advertising. This includes any personal information processed through
   Oracle Advertising’s Moat or Grapeshot products on behalf of Oracle
   customers. To find out more about our customers’ use of first-party
   information about you, you are encouraged to review the relevant privacy
   policy of the company who collected your information from you or is sending
   you advertising. Please consult that company if you have any further
   questions about its use of information about you.
 * Data collected for Oracle’s own direct marketing purposes. For information
   about Oracle’s processing activities with regard to your personal information
   collected on Oracle websites and applications, and used for Oracle’s own
   direct marketing purposes, please refer to
   https://www.oracle.com/legal/privacy/privacy-policy.


3. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?

Oracle Corporation and Oracle America, Inc., having their registered address at
2300 Oracle Way, Austin, TX, 78741, USA, are responsible for processing your
personal information in scope of this Privacy Policy.


4. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?

Information about you may in some cases directly identify you, while in other
cases it may only indirectly identify you. Personal information that is
collected offline and that can directly identify you may include, for example:

 * name, physical address, email addresses, and telephone numbers;
 * demographic attributes, when tied to other information that identifies you;
 * transactional data based on your purchases, when tied to other information
   that identifies you;
 * company data such as the name, size, and location of the company you work for
   and your role within the company;
 * data from marketing opt-in lists, consumer surveys, or publicly available
   information;
 * derived latitude/longitude from a physical address.


Oracle Advertising only processes offline personal information about individuals
located in the United States.

Personal information that is collected online and that may indirectly identify
you may include, for example:

 * unique IDs such as your mobile device identifier, or a cookie ID on your
   browser;
 * a connected device identifier such as an ID from a smart television or
   streaming device (US only);
 * IP addresses and information derived from IP addresses, such as geographic
   location;
 * information about your device, such as browser, device type, operating
   system, the presence or use of “apps”, screen resolution, or the preferred
   language;
 * obfuscated personal information such as hashed email addresses (direct
   identifiers are removed);
 * demographic information such as gender, age, and income range when not tied
   to information that directly identifies you;
 * behavioral data of the internet connected computer or device you use when
   interacting with websites, applications, or other connected devices, such as
   advertisements clicked or viewed, websites and content areas, date and time
   of these activities, or the web search used to locate and navigate to a
   website.


We may associate personal information about you with interest segments or
profiles as part of the provision of Oracle Advertising services to our
customers and partners:

 * Interest Segments are a specific group of consumers that share a common
   behavior or preference used for direct marketing by our customers. For
   example: in market for travel specials to Hawaii.
 * Profiles are a set of attributes about a specific consumer or device, or a
   set of multiple consumers or devices sharing common attributes used for
   marketing by our customers. For example: age bracket 25-55; adventurous
   traveler; surfing enthusiast; in market for travel specials to Hawaii.



5. FOR WHAT COMMERCIAL OR BUSINESS PURPOSE DO WE USE YOUR PERSONAL INFORMATION?

We use personal information for the following commercial purposes:

 * a) to help enable Oracle Advertising customers and partners to market
   products and services to you based on your interests;
 * b) to analyze, develop, improve, and optimize the use, function and
   performance of Oracle products and services;


We use personal information for the following business purposes:

 * c) to manage the security of our sites, networks and systems;
 * d) to comply with applicable laws and regulations and to operate our
   business.


These purposes are described below in further detail.

 * a) To help enable Oracle Advertising customers and partners to market
   products and services to you based on your interests


We process personal information about you for marketing purposes to help enable
Oracle Advertising customers and partners to advertise products and services to
you via online and offline marketing activities based on your interests.
“Marketing purposes” means the processing of offline and online personal
information, as defined in Section 4: (i) to solicit or induce a purchase,
rental, lease, or exchange of products or services directly to consumers or
businesses via offline and online advertising campaigns; (ii) to develop market
research or market surveys or to provide verification services to marketers;
(iii) to create, communicate, deliver, and exchange offerings that have value
for customers, clients, partners, and society at large; or (iv) to encourage
safe practices and trends and the provision of factual information, including,
by way of example, providing product or automotive recall notices.

More specifically, Oracle can process information about you:

 * i. For online interest-based advertising delivered through Oracle Advertising
   partners that display online advertising to you on behalf of Oracle
   Advertising customers.
   
   Example: a marketing professional working for a travel company wants to
   market the company’s travel specials to Hawaii to a specific group of
   individuals (also known as an audience) that may be interested in those
   specials. The marketing professional uses Oracle Advertising services to
   create an audience interested in travel to Hawaii. If you have visited a
   travel website previously and have expressed an interest in Hawaiian
   vacations, you may be placed in the travel company’s audience and
   subsequently see advertisements for a vacation to Hawaii on other websites
   (because a cookie has been placed on your browser) or, in the United States,
   via a connected device (due to an association between your IP address and
   device identifier).
   
   
 * ii. For offline and online campaign measurement, analytics, and development
   of insights on behalf of our Oracle Advertising customers.
   
   Example: a marketing professional working for a travel company wants to
   better understand if the company’s marketing campaign for travel specials to
   Hawaii contributed to an increase in their product sales. The marketing
   professional uses Oracle Advertising services to see how many display or
   videos ads were viewed, and whether the ads were clicked on and a purchase
   was made.
   
   
 * iii. For enabling our Oracle Advertising customers to personalize their
   products and services, including site optimization, email personalization,
   and dynamic marketing and advertising optimization.
   
   Example: if you have previously indicated an interest in travel to Hawaii,
   when you visit a travel company’s website it can display tailored offers for
   Hawaiian vacations on their homepage.
   
   
 * iv. For linking Profiles and Interest Segments to enable Oracle Advertising
   customers and partners to connect your Interest Segments across the various
   browsers and/or devices you may use for the purposes described in this
   section.
   
   Example: you are interested in vacations offered by a travel company and have
   clicked on their online advertising. You are logged into several devices
   (your desktop, smartphone, and tablet) using the same login. Oracle
   Advertising partners have indicated that you are likely the same user across
   those same devices. The travel company is able to display vacation offers to
   you (via a de-identified cookie ID) on these different devices.
   
   
 * v. For creating modelled online and offline “lookalike” audiences for Oracle
   Advertising customers’ products and services.
   
   Example: a marketing professional working for a travel company wants to find
   new potential customers who are, like you, likely to be interested in travel
   to Hawaii. Oracle Advertising services can help the travel company by looking
   for key characteristics between Profiles that have expressed an interest in
   traveling to Hawaii and other Profiles where a similar interest can be
   inferred based on these characteristics, such as an interest in travel to
   tropical islands.
   
   
 * vi. For enabling our Oracle Advertising customers to associate first-party
   information to certain Oracle Advertising identifiers in order to deliver
   marketing and advertising services to you.
   
   Example: A travel company has its own lists of customers who have purchased
   travel arrangements with them, with names, emails, and addresses. The travel
   company wants to be able to reach out to these customers with online
   advertising. The Oracle Advertising services can help the travel company by
   converting the company’s own customer lists from identified names, emails,
   and addresses, to de-identified groups of cookie and device IDs provided by
   Oracle Advertising, in a process known in the advertising industry as
   “onboarding”.
   
   
 * vii. For the United States only: to allow our customers to deliver catalogues
   to your physical address that may be of interest to you based on your
   previous offline purchase behavior.


 * b) For personal information collected outside the EU/EEA, to analyze,
   develop, improve, and optimize the use, function and performance of Oracle
   products and services
   
   We may process personal information for Oracle’s own research and development
   purposes.
   
   For example: to enhance data quality, develop new features and functionality,
   and for statistical analyses related to the performance and operation of
   Oracle Advertising services.
   
   
 * c) to manage the security of our sites, networks and systems
   
   We can collect usage and systems operations data from Oracle Advertising
   services for security and operations management to help keep Oracle,
   customer, and partner networks and systems, as well as our products and
   services, secure. We may also collect usage and systems operations data to
   investigate and prevent cyber-attacks, malicious activity, or potential
   fraud, including ad fraud and to detect bots.
   
   
 * d) to comply with applicable laws and regulations and to operate our business
   
   In some cases, we may process personal information to comply with applicable
   laws and regulations. For example, to respond to a request from a regulator
   or to defend a legal claim. We may also process personal information in the
   operation of our business. For example, to conduct audits and investigations,
   for finance and accounting, archiving, and insurance purposes.



6. CATEGORIES OF SOURCES OF PERSONAL INFORMATION

Oracle may process both offline and online information about you, including
information from publicly available sources or third party data providers.

 * Offline information about you is obtained by Oracle from its offline partners
   such as brick-and-mortar retail stores, grocery stores and their associated
   loyalty card programs, payment card brands, catalog orders and consumer
   survey programs, and third parties who may not have a relationship with you
   and collect offline information from their offline partners.
 * Online information about you originates from your activities on sites
   operated by our online partners, such as advertising agencies and website
   operators (for example, online retail stores or travel sites). Oracle also
   obtains online information from third parties who may not have a direct
   relationship with you and who collect online information using cookies or
   similar technologies, such as pixels tags and device identifiers, as you
   browse the Internet and interact with websites. For more information on
   cookies and similar technologies used in connection with Oracle Advertising
   services, please refer to Section 12 below.


Our online Oracle Advertising branded data partners are listed in our catalogue.
Please note that some of these partners only provide information about
individuals in specific regions.


7. FOR INFORMATION ABOUT YOU COLLECTED IN THE EU/EEA, WHAT IS OUR LEGAL BASIS?

Oracle Advertising only collects limited third party data about users located in
the EU/EEA, Switzerland, or the UK and only for legal compliance purposes,
including for data minimization and to avoid using data from these regions.
Specifically, upon initial collection, Oracle Advertising segregates,
obfuscates, and purges the data from users in these regions so as to prevent
using the data for the commercial purposes described above in Section 5 of this
Policy. Customers are responsible for their own first-party data collection and
processing practices. Please see “First-party information collected about you by
Oracle customers” under Section 2 for more information.


8. FOR WHAT PERIOD DO WE RETAIN INFORMATION ABOUT YOU?

Oracle maintains information about you for the following retention periods:

 * a) Online information about you is retained for up to 13 months.
   
   Certain online information may be retained up to 18 months. For example,
   Oracle customers’ seasonal or cyclical interest-based advertising campaigns
   or internal analytics and model development may be retained for up to 18
   months.
   
   
 * b) Online information about you for linkage purposes (cross
   device/cross-context technology) is retained for up to 12 months.
   
   
 * c) Offline information about you may be retained for as long as relevant for
   the purposes for which it was collected (see Section 5 above).
   
   
 * Personal information necessary to preserve opt-out preferences is retained
   for 20 years, unless you delete it or otherwise prevent its collection as
   further described in Section 13 below.



9. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

Sharing within Oracle

As a global organization, information about you can be shared globally
throughout Oracle’s worldwide organization for a business purpose(s). See a list
of Oracle entities. Please select a region and country to view the registered
address and contact details of the Oracle entity or entities located in each
country.

Oracle employees are authorized to access personal information only to the
extent necessary to serve the applicable purpose(s) and to perform their job
functions.

Sharing with or selling with third parties

We may share personal information with or sell personal information to the
following third parties for a commercial purpose:

 * Oracle Advertising customers and partners, including digital marketers, ad
   agencies, web publishers, connected TV providers, demand side platforms, data
   management platforms, supply-side platforms, and social media networks; and
 * third-party service providers as necessary to perform Oracle Advertising
   services on behalf of Oracle.


We may share personal information with the following third parties for a
business purpose:

 * relevant third parties in the event of a reorganization, merger, sale, joint
   venture, assignment, transfer, or other disposition of all or any portion of
   our business, assets or stock, including in connection with any bankruptcy or
   similar proceedings; and
 * public and government authorities, including public and government
   authorities outside your country of residence (to the extent legally required
   to respond to their mandatory requests in connection with national security
   and/or law enforcement purposes).


When third parties are given access to personal information, we will take
appropriate contractual, technical, and organizational measures designed to
ensure that personal information is processed only to the extent that such
processing is necessary, consistent with this Privacy Policy and in accordance
with applicable law.


10. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

Oracle is a global corporation with operations in over 80 countries, and
personal information is processed globally as necessary in accordance with this
policy. If personal information is transferred to an Oracle recipient in a
country that does not provide an adequate level of protection for personal
information, Oracle will take adequate measures designed to protect the personal
information, such as ensuring that such transfers are subject to the terms of
the EU Model Clauses or other adequate transfer mechanism as required under
relevant data protection laws.


11. HOW IS INFORMATION ABOUT YOU SECURED?

Oracle has implemented appropriate technical, physical, and organizational
measures designed to protect personal information against accidental or unlawful
destruction or accidental loss, damage, alteration, unauthorized disclosure or
access, as well as other forms of unlawful processing.


12. WHAT COOKIES, PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES DO WE USE?

Cookies and similar technologies (e.g., pixel tags and device identifiers) are
used by Oracle and our advertising technology partners to recognize you and/or
your device(s) on, off, and across different services and devices for the
purposes specified in Section 5 above.

Cookies are small text files that contain a string of characters and uniquely
identify a browser on a connected device. We or our Oracle Advertising partners
may use cookies to, among other things, track user trends and collect
information about how you use our customers’ sites or interact with advertising.
Most browsers are initially configured to accept cookies by default. You may,
however, be able to change your browser settings to cause your browser to refuse
third-party cookies or to indicate when a third-party cookie is being sent.
Check your browser’s “help” files to learn more about handling cookies.

Pixel Tags (also called web beacons or clear GIFs) are invisible 1 x 1 pixels
that are placed on webpages that use this technology for marketing and
measurement purposes. When you access these webpages, pixel tags generate a
generic notice of the visit. Pixel tags can be used with cookies or alone. When
used with cookies, pixel tags can track activity on a site by a particular
device and provide relevant online advertising to you. When you turn off cookies
or have opted out of cookies, pixel tags simply detect a unique website visit
and how you interacted with the advertising, but do not track an individual to
provide relevant online advertising.

You can opt out of cookies using the opt-out tools in the next section.


13. WHAT ARE YOUR PRIVACY RIGHTS?

Pursuant to the E.U. General Data Protection Regulation (GDPR), the California
Consumer Privacy Act (CCPA), and other applicable laws and regulations,
individuals in certain jurisdictions may have data subject rights enabling them
to request to opt-out of third party sharing or selling, delete or remove, or
request to access and receive a copy of their personal information in Oracle’s
possession or for which Oracle is otherwise responsible.

Opt-out and object to our use of information about you

Oracle offers multiple ways for you to opt out of third party sharing or selling
and object to our use of information about you:

 * Oracle Advertising Opt-out. Access the Oracle Advertising opt-out tool.
   
   Please note that if you use this opt-out tool, Oracle will opt you out of
   Oracle’s use of information about you for Oracle Advertising services
   involving both first-party use of your information as well as any third-party
   sharing or selling of your information. See Section 2 above for more
   information on the distinction between first-party and third-party
   information.
   
   The Oracle Advertising opt-out will prevent Oracle from delivering
   third-party audiences to connected devices such as smart televisions or
   streaming devices; however, you can also visit your device’s settings menu or
   privacy policy for information on how to opt-out directly with your connected
   devices.
 * AdTech Industry Opt-Out. You may also opt-out of third-party sharing or
   selling by Oracle Advertising services by using the opt-out tools provided by
   the following industry groups:
   * Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/
   * Network Advertising Initiative (NAI): http://optout.networkadvertising.org
   * European Interactive Digital Adverting Alliance (EDAA):
     http://www.youronlinechoices.eu/ and http://www.edaa.eu/
 * Mobile Opt-Out. While the opt-out methods described above often also work for
   mobile web browsing, mobile ‘app’ environments do not accept cookies. You may
   want to consider installing the AppChoices App provided by the Digital
   Advertising Alliance (DAA) to exercise opt-out control for specific
   companies, including Oracle, when in a mobile app environment. See more
   information on how to download and configure the AppChoices App relevant for
   your mobile platform. You can also visit the NAI’s website for more
   information and instructions on opting out on mobile devices.
 * Audience Matched Advertising Opt-Out. Oracle Advertising provides “Audience
   Matched Advertising” where Oracle Advertising uses hashed emails to create
   tailored digital advertising to provide Oracle Advertising online services.
   The NAI provides an email-based opt-out to opt-out of this activity. Please
   visit the NAI’s website for more information and instructions on opting out
   of Audience Matched Advertising.
 * Do Not Track. Oracle honors “Do Not Track” browser settings, meaning we will
   not track your browser for marketing purposes while you have “Do Not Track”
   turned on in your browser settings.

Please note that if you opt-out using any of the first three opt-out tools, you
may still temporarily see interest-based advertising from Oracle Advertising
customers due to advertising campaigns from those customers already underway.
However, you will be opted-out of all future advertising campaigns from
customers that use Oracle Advertising services.

Also note that the first three opt-out tools are currently cookie-based and
prevent Oracle from using, sharing, or selling your personal information for
interest-based advertising on the browser on which they are installed. As a
result, these opt out tools will only function if your browser is set to accept
third-party cookies and may not function where cookies are sometimes
automatically disabled or removed (e.g., certain mobile devices and operating
systems). If you delete cookies, change your browser settings, switch browsers
or computers, or use another operating system, you will need to opt out again.
Oracle does not use persistent, unique identifiers to revive a previously
opted-out profile or deleted cookie.

If you want to opt-out of Oracle’s use of information about you for Oracle
Advertising services, and do not want to receive third-party cookies, you can
also change your browser settings on your computer or other device you are using
to connect to the internet. Most browsers also provide functionality that lets
you opt-out of all advertising cookies, including Oracle cookies.

Delete information about you

You can erase or delete all online information about you by opting out of Oracle
Advertising services using the Oracle Advertising opt-out tool above.

If you would like to submit a request to have offline information about you, if
any, erased or deleted, you can use this form.

Access information about you

In order to exercise your right to access your online information processed by
Oracle Advertising, you can use the Oracle Advertising Registry (‘Registry’) to
view the online segments Oracle has associated with your device. By accessing
this Registry, you can view the types of third-party interest segments that are
shared with or sold to Oracle Advertising customers. Please note that the
interest segments you see within the Registry is information from the profile
associated with the specific browser, computer, or device that you are using to
visit the Registry. You may see different segments when viewing the Registry
from a different browser, computer, or device. For a complete picture of the
segments associated with all of your browsers and devices, we therefore
recommend using these different browsers and devices when accessing the
Registry.

To request access to your offline information, please visit the Oracle
Advertising access site, available at
https://datacloudoptout.oracle.com/request-your-data. While the majority of
offline access requests can be handled quickly, complex requests may take more
research and time. In such cases, you will be contacted regarding the nature of
the request and appropriate next steps within 45 days from the date of receipt
of your request. Upon visiting the Oracle Advertising access site, you will be
asked to verify your identity to submit your request. If you cannot verify your
request via the online portal, you can submit a written request via postal mail
to the Oracle Global Data Protection Officer at the address below with a copy of
a government-issued ID or other proof of identity for verification purposes. We
cannot provide access to offline data unless Oracle can verify the identity of
the individual making the request. Oracle Advertising only processes offline
data on residents within the United States.

We cannot provide offline first-party information that is collected and
maintained by our customers. If you have questions in regards to first-party
information, Oracle recommends that you contact directly the company that
collected it from you.

We will respond to your request consistent with applicable law. Oracle will not
discriminate against consumers who have exercised the deletion, opt-out, or
access rights provided to them in this Privacy Policy.

Deceased Do Not Contact Registration with the DMA. We recognize that receiving
mail for a deceased loved one can be difficult for family members, friends, or
caretakers. You can opt-out your loved one using the Oracle Advertising opt-out
tool; however, Oracle’s opt-out tool is limited to only Oracle’s use and sharing
of your loved one’s personal information. We recommend using the DMA Deceased Do
Not Contact Registration to remove the names of your deceased loved ones from
commercial marketing lists for all companies that ingest this list, available
here: https://www.ims-dm.com/cgi/ddnc.php.


14. DOES ORACLE ADVERTISING COLLECT SENSITIVE PERSONAL INFORMATION?

Oracle does not create any online interest segments that reflect personal
information that we consider sensitive. We also have operational procedures in
our platform designed to prevent our partners and customers from using personal
information provided to them by Oracle to create interest segments that we
consider sensitive. While the types of personal information considered sensitive
may vary among consumers and applicable law, we treat the following types of
personal information as sensitive:

 * precise health, biometric, or genetic information, such as a certain
   sensitive medical condition like cancer or diabetes;
 * pregnancy, such as pregnancy choices, pregnancy termination, reproductive
   rights, and traveling to exercise reproductive rights;
 * certain aspects linked to personal life, such as religious, political, or
   sexual orientation;
 * interest in "adult" activities, such as drug use, an interest in weapons, or
   pornographic material; and
 * information considered sensitive based on applicable law.


In addition, Oracle prohibits all segments in the EU/EEA, Switzerland, and the
UK that fall into any of the following categories: health/biometric/genetic, sex
life or sexual orientation, race or ethnicity, religious /philosophical beliefs,
political affiliations and opinions, any information related to children under
16, criminal offenses or convictions, or membership in a union. Similar or
additional restrictions may apply in other regions.

We do not allow Oracle Advertising customers or partners to use data provided to
them by Oracle: (i) to make decisions related to an individual’s eligibility for
employment, credit, healthcare, insurance, tenancy, or education purposes; (ii)
to make decisions solely by automatic means where the decision has a significant
effect on the individual; or (iii) in any way that may or does discriminate
against any person or promote bigotry, racism, or harm. For these purposes,
Oracle considers harm to be inclusive of the use of data provided by Oracle to
target vulnerable individuals or groups with fraudulent or deceptive marketing
campaigns or to be used in any manner that causes vulnerable individuals harm.

As noted above, Oracle Advertising does not created interest segments that
reflect sensitive medical conditions. For a list of Oracle Data Cloud's
non-sensitive health and wellness segments, please see this link (PDF).


15. DOES ORACLE ADVERTISING COLLECT PERSONAL INFORMATION FROM CHILDREN?

We do not intentionally collect or share personal information of children under
16 years of age or allow the creation of segments targeting children under 16
years of age. Further, we prohibit our Oracle Advertising partners from
providing Oracle with personal information from sites directed to children under
the age of 16 or from consumers whose age these companies know to be under the
age of 16.


16. IS ORACLE A MEMBER OF ANY INDUSTRY ORGANIZATIONS?

Oracle is a member of, and adheres to, the self-regulatory principles of the
following industry organizations:

 * the Data Marketing & Analytics (ANA)
 * the Direct Marketing Association UK (DMA UK);
 * the Network Advertising Initiative (NAI);
 * the Interactive Advertising Bureau (IAB);
 * the Digital Advertising Alliance (DAA);
 * the Digital Advertising Alliance of Canada (DAAC); and
 * the European Digital Advertising Alliance (EDAA).


As a member of these organizations, Oracle works with industry-leading companies
to address important privacy and consumer protection issues in offline direct
marketing and online advertising.

The NAI has created a compliance program that incorporates attestation reviews,
a consumer complaint process, sanctions and annual reporting to help ensure that
member companies keep their promises to you and abide by the NAI’s
Self-Regulatory Code of Conduct.


17. WHAT ARE YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)?

If you are a California resident, you may request that we:

 * 1. disclose to you the following information covering the 12 months preceding
   your request:
   
   
   * the categories and specific pieces of personal information we collected
     about you and the categories of personal information we sold (see Section
     4);
   * the categories of sources from which we collected such personal information
     (see Section 6);
   * the business or commercial purpose for collecting or selling personal
     information about you (see Section 5); and
   * the categories of third parties to whom we sold or otherwise disclosed
     personal information (see Section 9).
 * 2. delete personal information we collected from you (see Section 13); or
 * 3. opt-out of any future sale of personal information about you (see Section
   13).


Oracle will not discriminate against you if you exercise these rights under the
CCPA.

We will respond to your request consistent with applicable law. If you are an
authorized agent making an access or deletion request on behalf of a Californian
resident, please reach out to us via the inquiry form and indicate that you are
an authorized agent. We will provide you with instructions on how to submit a
request as an authorized agent on behalf of a Californian resident.

If you are a California resident, you may obtain information about exercising
your rights, as described above, by contacting us at 1-800-633-0748. For
information on the CCPA requests Oracle received, complied with, or denied for
the previous calendar year, please visit Oracle’s Annual Consumer Privacy
Reporting page, available here.


18. HOW TO CONTACT ORACLE IF YOU HAVE QUESTIONS, COMMENTS, OR COMPLAINTS?

Oracle has appointed a Global Data Protection Officer. If you believe your
personal information has been used in a way that is not consistent with the
Privacy Policy or your choices, or if you have further questions, comments, or
suggestions related to this Privacy Policy, or if you wish to exercise your
right to access to your offline personal information as described in Section 13
above, please contact the Global Data Protection Officer by filling out an
inquiry form.

Written inquiries to the Data Protection Officer may be addressed to:

Oracle Corporation
Global Data Protection Officer
Willis Tower
233 South Wacker Drive
45th Floor
Chicago, IL 60606
U.S.A.


19. FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy,
please contact us. We will investigate and attempt to resolve complaints and
disputes regarding use and disclosure of personal information in accordance with
this Privacy Policy and in accordance with applicable law. You also have the
right to file a complaint with a competent data protection authority if you are
a resident of a European Union member state.


20. ORACLE CORPORATE HEADQUARTERS

Oracle’s corporate headquarters are located at:

2300 Oracle Way
Austin, TX 78741
USA

Tel: +1.737.867.1000

Previous versions: 5/5/22 | 10/31/21 | 4/13/21 | 1/4/21 | 10/20/20 | 6/11/20 |
12/24/19 | 7/26/19 | 1/17/19 | 5/25/18 | 2/13/18

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