Privacy Policy

Online Privacy Statement

Effective date: December 20, 2019

Vocera Communications, Inc. (“Vocera”, “we”, “our”, or “us”) operates the site located at (“Site”) and provides the content (including email and electronic communications) and services (collectively “Services”) offered on or through the Site. “Platform” means the “Site” and/ or “Service”.

This Privacy Statement explains how we collect, use, share and protect information about visitors or registered users on, from or through the Platform and the choices that visitors and registered users have about the collection and use of certain information about them.

1. Scope

This Privacy Statement applies solely to information that we collect from visitors and registered users from or through the Platform or through electronic communications that we receive at the address indicated in section “How to Contact Us,” and to information that we may obtain from third parties.It does not apply to the devices, services, systems and software that we provide to our customers.

A “visitor” is an individual who visits the Platform, without having registered. We do not know the identity of the individual. A “registered user” is an individual who has registered with the Platform, and whose identity can be determined directly or indirectly from the information provided. For the purpose of this Privacy Statement “you” means a visitor or a registered user; and a “visitor” includes a “registered user”.

This Privacy Statement does not apply to the websites of third parties to which the Platform may link. We do not endorse, and are not responsible for the content of these websites, their policies or practices, or any product or service that they may offer. Any activity you perform on these third-party websites will be subject to the privacy policies and other terms and conditions of these third parties. We recommend that you review these third-party terms before providing any personal information to them. 

2. Consent

By using the Platform, you signify your agreement to the terms of this Privacy Statement. Please ensure that you read this Privacy Statement carefully.

Visitors from Outside the United States

Because the Internet is global, information about visitors may be transferred to, processed in, and held in countries (including the United States) other than the one in which the visitor resides, which may have different data privacy laws and practices than the country where the visitor resides.

By using our website, you explicitly consent to such use of your information in a country other than the country where you reside. If you do not consent to such use, please email us at the address provided in the “How to Contact Us” section.

Information for EU Users

Some of the processing we conduct will involve making decisions about you based on automated processing of your personal information. For example, we may conduct profiling activities to select personalized offers or recommendations for you based on your use of the Platform and browsing history. If you are in the EU, where these decisions are based solely on our automated processing of your personal data (i.e., not subject to human review), these types of decisions will not have legal or similar effects on you, but you can still contact us for further information and to object to this use of your personal information by emailing us at the address provided in the “How to Contact Us” section.

Under EU privacy law, we must have a legal basis to process personal information. In most cases, the legal bases for our processing, under EU law, will be one of the following:

  • to comply with our legal and/or regulatory obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations; and/or
  • in connection with the performance of a contract to which you might be a party; or to take necessary steps before entering into a contract; and/or
  • to meet our legitimate interests, for example to: understand how you use the Platform and to enable us to use this knowledge to improve our products and services and to develop new ones; to communicate with you about the products and services that you use or we offer; maintain our accounts and records; to assess patterns of use; and to plan and evaluate our marketing and business development programs. For example, we believe that as a professional in our industry you are interested in knowing about new developments and new products, and that it is in your best interest to receive communications about events, trends, products and technology in your industry. We also use appropriate safeguards designed to protect your privacy interests, freedoms, and rights under applicable laws.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to some direct marketing activities, our use of cookies and tracking technologies or when we process sensitive personal information). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details located in the “How to Contact Us” section at the end of this Privacy Statement.

We may anonymize your personal information and use it for other purposes. For example, we may prepare aggregated reports about how users interact with the Platform for research.

3. How We Obtain Information

We (and our service providers) obtain information about visitors in a variety of ways, such as through the methods identified below:

  • From the visitor’s browser, such as the screen resolution, operating system name and version, device manufacturer and model, language, or browser type and version.
  • Through a visitor’s activities offline, for example when a visitor responds to a newsletter or interacts with us by telephone.
  • Through the visitor’s activities online when using the Service – for example, taking a course, filling out an online form, requesting white papers or responding to surveys and other questions.
  • Through a visitor’s social media account if it is connected to the visitor’s account on our Platform.
  • Through cookies and other technologies that help analyze how our Platform is used, measure and track general visitor activities, and on third party websites and compile statistical reports
  • By receiving additional information from third parties, such as entities that collect information about persons or companies that may be interested in our products or services.

4. What Information We Obtain

We collect information from visitors when they interact with the Platform. This includes the following:

Information We Collect Automatically

When a visitor uses or interacts with our Platform, the visitor’s browser automatically provides, and we automatically collect and store, certain information about the visitor’s device (computer, tablet, smart phone) and the visitor’s activities. This includes, for example:

  • Preferences and settings: time zone, language, and character size;
  • Identifiers: IP address, mobile device advertising identifier, Media Access Control (MAC) address;
  • Technical information: type of device, operating system name and version, device manufacturer, model, browser information (type, version), screen resolution, installed applications, uninstalled applications, applications running in the background;
  • Connection: Internet service provider or mobile carrier’s name, country, connection speed and connection type, Bluetooth settings;
  • Information about use of the Platform: date stamp, URL of the last webpage visited before visiting our Platform, and URL of the first page visited after leaving our Platform, pages viewed, time spent on a page, click through, clickstream data, queries made, search results selected, comments made, search history, type of service requested, purchases made;
  • Information collected through cookies, pixel tags, and other technologies; and
  • General geographic location.

When you browse our website, you do so anonymously, unless you previously have registered with our Platform and have indicated that you wish Vocera to remember your login and password for your future visits.

Communications and Interaction

Vocera collects visitors’ information through its Platform when a visitor
  • Registers for a Vocera account;
  • Uses certain Vocera products or services;
  • Registers to attend a seminar or participate in an online survey;
  • Asks to be included in an email or other mailing list;
  • Submits an entry for a sweepstakes or other promotion;
  • Contacts Vocera for customer support; and
  • Submits information to Vocera for any other reason (e.g., a credit card number or shipping address in the
  • course of a purchase through the Platform).

We collect and store certain information about the visitor, the visitor’s device (computer, tablet, smart phone) and the visitor’s activities, such as:

  • The visitor’s name, login ID or pseudonym, and contact information (if provided);
  • Information that the visitor provides or comments that the visitor makes;
  • The nature of the communication;
  • The purpose of the interaction, and the action we took in response to the visitor’s inquiry or request;
  • Whether the visitor opened our communication or ignored it;
  • The pages or features of our Platform that the visitor visits or views; and
  • Any action the visitor takes upon receipt of such communication.

Customers; Customers’ Employees

Access to certain Vocera web pages requires a login and a password. The use of those web pages, and the information or programs downloadable from those web pages, may be governed by a written agreement between your employer and Vocera.

Unless you request deletion of your personal information as specified below, your personal information may be retained by Vocera to verify compliance with that agreement, log software licenses granted, track software downloaded from those pages, or track usage of other applications available on those pages.

Social Media

Our Platform includes social media features that may be managed by us or by third parties. These features may collect a visitor’s IP address and which pages the visitor is visiting, and a cookie enables the feature to function properly. Your use of these third-party social media services may result in the collection or sharing of information about you by these third-party websites and social media services.

We encourage you to review the privacy policies and settings of the third-party websites and social media services with which you interact to make sure you understand what information may be collected, used, and shared by those third-party websites and social media services.

Information We Obtain from Third Parties

We may obtain information from third parties with whom we do business, such as strategic business partners, service providers, public databases, social media services to which our Platform might be linked, or providers of databases of leads. The types of information we typically obtain are names, employers, job locations and job titles, addresses, email addresses and phone numbers.


We work with third party analytics services to help us understand how the Platform is being used, such as the frequency and duration of use of the Service. These analytics services providers use cookies and similar technologies to collect information about the content visitors view, what websites visitors visit immediately prior to and after visiting the Platform, or the visitors’ system’s information and coarse geographic information. The information generated by these cookies and other technologies is transmitted to and stored by the applicable analytics services.

We use other analytics technologies to understand better our market, the profile of potential customers, or to derive information about a person’s interest in our product or services based on the person’s usage patterns.

5. How We Use Information

Vocera uses information to:

  • Facilitate the visitor’s use of the Platform;
  • Remember the visitor’s preference, such as language and font size, when using our Platform;
  • Allow the visitor to navigate or browse through the Platform quickly and efficiently;
  • Keep records of contact information and correspondence;
  • Send invitations to events that may be of interest to the visitor in accordance with the visitor’s preferences or apparent interests;
  • Facilitate social sharing functionality, such as sharing content, through social media networks;
  • Allow the visitor to share content with a friend through the Platform; by using this feature, you guarantee that you have the right to use and provide us the names and email addresses you submit.
  • Fulfill requests for information on certain products and services;
  • Respond to customer support inquiries;
  • Fulfill orders for products or services;
  • Remember the visitor’s interests;
  • Personalize a visitor’s experience on the Platform by presenting content that is tailored to that specific visitor based on what we know about that visitor;
  • Keep visitors up to date on the latest product announcements, software updates, special offers or other information regarding Vocera or its business partners;
  • Better understand each visitor’s needs;
  • Administer our Platform, diagnose technical problems, and otherwise manage our business;
  • Attempt to identify potential customers or entities that might have a use for our products or services;
  • Send administrative information to the visitor;
  • Optimize our marketing efforts, for example by compiling statistics regarding the use of the Platform, identifying usage trends, or measuring the effectiveness of our promotional campaigns;
  • Send, or have our business partners send on our behalf, direct marketing information to visitors;
  • Communicate with visitors about our activities;
  • Contact visitors for market research;
  • Improve, test, and monitor the effectiveness of the Platform;
  • Develop features for the Platform that may be of interest to visitors;
  • Perform data analysis, audits, security and fraud monitoring and prevention;
  • Enhance, improve, or modify the Platform; identify usage trends; and
  • Help diagnose server problems, and detect spam behavior, denial of service attacks or similar incidents.

6. Information Sharing and Disclosure 

Except as described in this section, Vocera will not transfer to third parties information about a specific visitor without your consent.

Employees; Service Providers

We have employees in the United States, United Kingdom, Canada, Australia, the United Arab Emirates and India who may have access to personal information in order to provide a product or service that a visitor requested. We also may share personal information with third parties who provide services to us (e.g., credit card processing services, shipping services, mailing services, marketing services or data management and storage services) or who work on our behalf to provide a product or service that a visitor requested. In those circumstances, we disclose the personal information that is necessary for such third parties to perform those services and request that they not share such personal information in a manner inconsistent with this Privacy Statement. Personal information collected may be stored and processed in the United States or any other country in which we or our subsidiaries, affiliates, agents or partners maintain facilities, and by using this website, you consent to any such transfer of information outside of your country.

Aggregated Information

We may share aggregated information with third parties. We will not share any aggregated data, however, in a manner that would enable the recipient to personally identify you.

Legal Requests and Preventing Harm

We may share personal information:

  • In response to subpoenas, court orders, or legal process,
  • To establish, protect, or exercise our legal rights or defend against legal claims;
  • If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property; or
  • If we believe it is necessary to investigate, prevent, or take action regarding significant abuse of our website’s infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information).


We may share some or all of our visitors or registered users’ information with our parent company, subsidiaries, or other companies under common control with us; in this case we will require such entities to honor this Privacy Statement.

If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out of this sharing by emailing us at the address provided in the “How to Contact Us” section.

Change of Control

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any visitor information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information about other visitors or users to the relevant third parties participating in the relevant transaction.

Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred visitor information will be subject to this Privacy Statement. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

7. Your Privacy Choices

Visitors have numerous choices regarding information pertaining to them.

Advertising Choices

Please visit the section Advertising Choices

Electronic Communications

If you receive commercial electronic communications from us, you can unsubscribe from the receipt of future commercial electronic communications from us by clicking on the “unsubscribe link” provided in such communications. Please also note that if you opt out of receiving emails from us, we may still send you important administrative messages (such as updates about your account or service changes), and you cannot opt out from receiving these messages.

We may need to retain certain information for record keeping purposes and/or to complete any transaction that you began before requesting a change or deletion. In addition, it is likely that residual information might remain within our databases, back-ups or other records and might not be removed.

Data Sharing for Direct Marketing Purposes /Opt-Out

We give you the opportunity to "opt out" of our using your personal information to send you direct marketing or market research information. This means we assume you have given us your consent to use and disclose your personal information for such purposes unless you take affirmative action to indicate that you do not consent.

If you would like to opt-out as described above, please let us know either by clicking or checking the appropriate option or box at the point of collection of information or by contacting us as indicated in the “How to Contact Us” section.  See also our Advertising Choices disclosures.

Please note that sometimes these requests may take up to thirty (30) days to process.

Even if you do take advantage of these opportunities, we reserve the right to send you administrative messages relating to our website (e.g., about changes to this Privacy Statement), to contact you regarding orders you have placed (e.g., order confirmations and shipment tracking information), and to otherwise share your information with third parties as permitted under this Privacy Statement.

Changing and Managing Your Information.

If you are a registered user of the Service, you may make changes to the information you have provided in connection with your account by logging in to your account and changing the applicable information. You may also request changes by contacting us at the address provided in the “How to Contact Us” section. Following receipt of a request from you, we will take reasonable steps to update, correct or delete your information as requested.

Review and Deletion of Your Account and Information

You can contact us as indicated in the “How to Contact Us” section to request that your personal information be deleted from our database.

Please note that any personal information that we have collected may remain in back-up storage for some period of time after your request, and that if you delete certain personal information you may not be able to order services in the future without re-submitting such information. Also, please note that we will maintain personal information in our database whenever we are required to do so by law.

8. Data Security

Your Vocera account information is password-protected for your privacy and security. Vocera safeguards the security of the data you send us with physical, electronic, administrative, and managerial procedures. In certain areas of our websites, Vocera uses industry-standard SSL-encryption to enhance the security of data transmissions.

While we strive to protect the information that we collect, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.

You are responsible for protecting your login ID and password from third party access, and for selecting passwords that are secure.

We work with a payment processing company to process payment card information. We do not have access to payment card information details, and are not responsible for any loss of such information.

9. Children and Privacy

Children Under 16

Our website does not target and is not intended to attract children under the age of 16. Vocera does not knowingly collect or maintain personal information of children under the age of 16 or send them requests for personal information.

By using the Platform, you represent that you are at least 13 years old.

Right of Erasure

In addition, if you are a California resident under the age of 18 and are a registered user, California law allows you  to request that we remove content or information that you posted on Service or stored on our servers by submitting a request by email to the address provided in the “How to Contact Us” section. In your request, you must clearly identify the content or information you wish to have removed and provide sufficient information to allow us to locate the content or information to be removed.

10. Links to Third-Party Sites or Applications

The Platform may contain links to application or services operated by other companies. These links are provided for your convenience only and should be used at your discretion. These links do not constitute sponsorship, endorsement, or approval of the content, policies or practices of such third-parties’ applications.

Although we choose our business partners carefully, this Privacy Statement does not apply to information provided to or gathered by third parties that operate these other websites or applications. Vocera is not responsible for the privacy practices of websites operated by third parties that are linked to our website. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

11. Rights of California Residents

Scope of this Privacy Notice

This privacy notice describes the personal information Vocera collects or processes about California residents in connection with the Platform, how we use, share, and protect that personal information, and what your rights are concerning personal information that we collect or process.

In this privacy notice, “personal information” has the same meaning as under the California Consumer Privacy Act (CCPA), California Civil Code Section 1798.83: information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that has been de-identified or aggregated.

Personal Information Vocera Collects and Shares, and For What Purpose

In the past 12 months, Vocera has collected and shared personal information from visitors in the following circumstances when they interact with the Platform, as described in detail above in Section Four, “What Information We Obtain”:

  • Information We Collect Automatically
  • Communications and Interaction
  • Customers; Customers’ Employees
  • Social Media
  • Information we Obtain from Third Parties
  • Analytics

As described in detail above in Section Five, “How We Use Information,” Vocera uses personal information from visitors for a variety of purposes to operate, assess activity on, and improve the performance of the Platform.

Except as described in detail above in Section Six, “Information Sharing and Disclosure,” Vocera will not share with third parties information about you without your consent.

Vocera does not sell personal information to any third parties and has not done so in the last 12 months.

Your Rights as a California Resident

Under California law, Platform users who are California residents have specific rights regarding their personal information. These rights are subject to certain exceptions described below. When required, Vocera will respond to most requests within 45 days unless it is reasonably necessary to extend the response time.

Right to Disclosure of Information

You have the right to request that Vocera disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

  • The categories of personal information we have collected about you in the last 12 months.
  • The categories of sources for the personal information we have collected about you in the last 12 months.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold your personal information for a business purpose, a list of the personal information types that each category of recipient purchased.
  • If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.

Right to Delete Personal Information

You have the right to request that Vocera delete any of your personal information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your personal information, we will do so unless otherwise authorized by law.

How to Exercise these Rights

Information on how to submit a verifiable consumer request to Vocera for disclosure or deletion of personal information is available at Communication Preferences

We will respond to verifiable requests for disclosure or deletion of personal information free of charge, within 10 days of receipt.

In order to protect your privacy and the security of your information, we verify consumer requests by reviewing the information you provide and, if necessary, contacting you to confirm your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and Vocera may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

Right to Opt Out of Sales of Your Personal Information

You have a right to opt-out of the sale of your personal information. You may, at any time, direct businesses that sell your personal information to third parties not to sell your personal information.

We do not sell your personal information and therefore do not provide any mechanism for you to exercise the right to opt out.

Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.


Vocera does not knowingly collect or maintain the personal information of children under 13. If Vocera learns that we have collected any personal information of a child under the age of 13 without affirmative authorization under the CCPA or verifiable parental consent under the Children’s Online Privacy Protection Act (COPPA), Vocera will delete that information from our files as quickly as possible. If you believe that Vocera may have collected information of a child under 13, please contact us at the email address provided below.

12. Changes to this Privacy Statement

Vocera may amend this Privacy Statement from time to time. If we make any substantial changes to the way in which we collect or process information, we will inform our visitors as required by applicable law. Any updated version of this Privacy Statement will be effective as of the date set forth therein.

If you do not agree with the proposed changes, you should discontinue your use of the Platform before the new Privacy Statement takes effect. If you continue using our Platform after the new terms take effect, you will be bound by the modified Privacy Statement.

13. How to Contact Us

If you have questions or concerns about our collection, use, or disclosure of your personal information, please contact us as follows:


Mail: Vocera Communications, 525 Race Street, San Jose, CA 95126

This document was last updated December 20, 2019.

Effective Date: December 20, 2019

Advertising Choices

1. Cookies and other Tracking Technologies

We use cookies, beacons, pixels, tags, statistical IDs, flash cookies, and similar tracking technologies to collect information about the activities of our visitors and registered users over time and across different Sites, such as the pages a visitor views, the links on which a visitor clicks, how frequently a visitor accesses the Platform, and other actions a visitor takes.We also collect log file information from a visitor’s browser such as web request, IP address, browser type, referring / exit pages and URLs, and landing pages. We may use statistical modeling tools to attempt to recognize visitors across multiple devices.

We may retain the services of third party service providers who may link personal information about a visitor - such name or email address - to other information they may have – for example, past purchases. This information may allow us to identify assumed interests or preferences of that visitor, so that we can provide a visitor with more useful and relevant ads.

We use these technologies to:

  • Display information more effectively;
  • Gather statistical information about the use of the Platform to understand how our Platform is used, and improve design and functionality;
  • Store, on a visitor’s device, information about that visitor’s preferences and settings;
  • Recognize a visitor when the visitor moves from page to page, or returns to use the Platform;
  • Collect information such as browser type, time spent on the Platform, pages visited, and traffic data;
  • Track responses to our marketing and advertising campaigns; and
  • For security purposes.

We also use these technologies to understand the activities and interests of our visitors, including to:

  • Measure traffic and usage of our Platform
  • Monitor the effectiveness of our Platform
  • Better understand the interests of visitors
  • Recognize new or past visitors
  • Present more personalized content and advertisements
  • Optimize a visitor’s shopping experience
  • Identify visitors across devices, and on third party websites.
  • Identify improvements or enhancements to our Platform that might be of interest to our visitors

How to block Cookies

You can control some of our use of cookies. How you do so depends on the type of cookie. You may be able to configure certain browsers to delete or disable browser cookies. Most browsers contain information on how to control or delete cookies. These settings will typically be found in the “options” or “preferences” menu of a browser. You may also wish to refer to and for information on commonly used browsers.

To control flash cookies, you can visit:

Please note that blocking or disabling certain cookies may interfere with certain functionalities of some parts of our Platform. Choices you make about cookies are also browser and device specific. Further, while disabling a cookie may prevent the future collection of information, it does not prevent the use of information collected before the cookie was disabled. If you block or delete cookies, not all of the tracking described in this notice will stop.

2. Analytics

Information collected by Google Analytics is transmitted to, and stored by, Google in accordance with its privacy practices. To see an overview of privacy at Google and how this applies to Google Analytics, please click here:

To opt out of Google Analytics, please go to

3. Interest-Based Advertising

We may, or may have third parties, display to a visitor interest-based advertising and other custom content regarding our capabilities, products or services that may be of interest to visitors. These advertisements may be served to a visitor on or through our Platform, or on third-party websites. They may be based on interactions that a visitor has had with us or our Platform, on other activities and behaviors that the visitor demonstrates online, assumed interests attributed to that visitor, browsing history, and other information gathered about that visitor over time across multiple sites.

To collect this information, our service providers may place or recognize a unique cookie on the visitor’s browser and use other techniques, such as pixel tags. If you are using one of our mobile applications, our ad network partners may use and store your mobile device ID or Advertising ID to show ads that they consider relevant to you.

Do Not Track

Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Consequently, due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law. However, please note the capabilities below.

How to Opt-out of Interest Based Advertising

You may opt-out of receiving interest based advertising as explained below. The opt-out may be provided through specific tracking opt-out cookies. Please note that if you get a new computer, install a new browser, or erase or alter your browser’s cookie file (including upgrading certain browsers), this may also clear any opt-out cookie.

To opt out of receiving interest based advertising from advertising networks that may be delivered a website, visit the following websites, and follow the instructions: and

In addition, some third-party businesses may provide a mechanism to opt-out of their technology. For more information about the opt-out process, you may visit the Network Advertising Initiative, you may want to visit:  and

Mobile device visitors may also download the AppChoices app at: to opt out from interested based advertising served in mobile apps.

The features above will allow a visitor to opt out of many –but not all - of the interest-based advertising activities in which we or third parties engage.

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