1. Introduction
This website is presented by MARS Advertising, Inc. d/b/a The Mars Agency (“TMA”).  TMA cares deeply about your privacy and wants you to understand how we collect and use information that relates to you. We do not gather personally identifiable information (“PII” defined as your name, address, e-mail address, telephone number, fax number, demographic information, and/or information about your interests in and use of various products, programs and services, etc.). We do however gather non-personally identifiable and aggregated information about those who engage with the content we are involved with. Non-personally identifiable and aggregated information helps us to better understand how visitors use our website and apps.  We may share aggregated, non-personally identifiable information with our clients and affiliates.
2. Purpose of This Privacy Policy
This Privacy Policy explains how we handle non-personally identifiable and aggregated information that you share with TMA and/or we gather. As explained in detail below, our Privacy Policy is designed to provide notice to individuals regarding how their information is being collected and used.
3. Information Collection
A. PII Collected On Behalf Of Our Clients
In the event PII is collected by TMA on behalf of an identified client, such information belongs solely to the client and will be used solely in accordance with that client’s privacy policy.  Accordingly, we encourage you to review our specific client’s privacy policy when submitting information for their use.  An individual’s desire to “opt-out” of receiving marketing or other information from a client will be handled in accordance with the client’s privacy policy. TMA requests its clients to use the data that TMA collects on its behalf in accordance with generally accepted privacy standards for both offline and online data, which includes an “opt-out” method for individuals who have provided PII.  Ultimately, however, TMA is not responsible for data collected on behalf of its clients when such data is in its client’s possession.
B. Non-Personally Identifiable Information

In addition to information you voluntarily provide to us, TMA may collect on behalf of our clients and/or on our own behalf non-personally identifiable information (e.g., Internet Protocol (IP) addresses, device identifiers, “cookies,” browser information, Internet tags, and navigational data).  We do not attempt to associate such non-personally identifiable information with PII or with specific individuals.

C. Cookies

”Cookies” are small pieces of information that are stored by your web browser software on your computer’s hard drive or temporarily in your computer’s memory. The use of cookies is now an industry standard, and you will find them on most major web sites. TMA may place and store Internet cookies on a user’s hard drive. The use of cookies provides benefits to you by saving user names, information that are supplied at registration, and other information that may make the use of our programs easier. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas on a web site may not function properly if your web browser does not accept cookies.

D. Google Analytics

We use Google Analytics to collect information about visitor behavior on our website. Google Analytics stores information such as what pages people visit, how long they’re on the site, how they got here and what they click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are. We have turned on Google Analytics Demographics and Interest Reporting to get an idea of our demographics and users’ interests.  You can  opt-out here to prevent your data from being used by Google Analytics.

E. Analyzing Data

One of the ways TMA improves its solutions is by analyzing your data to create a more engaging and effective experience.  We may use the data provided by Google Analytics Demographics and Interest Reporting to develop the site and content around our users’ interests.  TMA may aggregate and anonymize data to provide better products which we share with third parties. TMA may share information created by using aggregated and anonymized data with affiliates, select business partners, and third parties.

4. Sharing and Use of Non-Personally Identifiable Information
We use the non-personally identifiable and aggregated information we collect to better understand how visitors to our website/apps engage with the content we are involved with, and to assess, improve, and quantify the response to such content.  We may share aggregated, non-personally identifiable information with our clients and affiliates.

5. Collection of Information by Third Parties and Links to Third-Party Websites

Our website may serve ads from and/or link to the websites of third-parties. Such third-parties may use automated methods to collect information about visitors to our websites.

6. Special Note About Children
Unless otherwise specifically indicated, TMA’s programs are not available to anyone under the age of thirteen (13).  We do not solicit PII from children, and no one under the age of thirteen (13) should submit PII to us.  If we discover that PII submitted to us pertains to a child under the age of thirteen (13), we will delete it.
7. California Privacy Rights
A. Rights of Minors
If you are a resident of the State of California and between the ages of thirteen (13) and eighteen (18), and have registered as a user of one or more of our website or apps, you may request the removal of content or information you have posted that can be accessed by other users, by updating your profile and/or preferences, Please note, however, that removal of content or information you have posted from our websites or services does not ensure complete or comprehensive removal of the content or information, particularly if the content or information you posted has been copied and/or reposted by a third party.
B. California Customers

Pursuant to California Civil Code Section 1798.83, a California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes, unless the business adopts and discloses to the public a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes if the customer “opts out” of such communications. In that case, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost-free means to exercise that right.  Our cost-free “opt-out” procedure is described in Section 3D, above.  If you use our “opt out” procedure, we will not disclose your personal information to third parties for the third parties’ direct marketing purposes.

C. Do Not Track Signals

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.

8. GDPR

TMA processes Personal Data both as a Processor and as a Controller, as defined in the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the “Directive”) and the GDPR.

TMA adheres to the Directive and the GDPR. Consequently, TMA processes all data provided by its Users with accounts in its United States and the European Data Region, in the European Economic Area (EEA) or the United States only.

All data collected by TMA will be stored exclusively in secure hosting facilities. TMA has a data processing agreement in place with its provider, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transmitters of data internally in the EEA and the United States is done in accordance with this data processing agreement.

9. Material Changes to Policy
TMA may make material changes to this Privacy Policy from time to time. Therefore, you should periodically visit this page to view the current Privacy Policy. Your continued use of our websites indicates your consent to the terms of our then-current Privacy Policy. In the event of a material change to this Privacy Policy, TMA shall send an email advising of the change to all persons whose email addresses we have collected and retained pursuant to the terms set forth above.
10TMA Data Protection Officer

TMA’s Data Protection Officer can be reached at the following address: Jason Hittleman, 25200 Telegraph Rd., Southfield, MI 48033; hittlemanj@themarsagency.com, 248.936.2457. You may contact TMA’s Data Protection Officer if you have any questions.