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PRIVACY POLICY
Updated: September 05, 2023
This Privacy Policy (“Privacy Policy”) informs about Personal Information
processed
through adMarketplace, Inc.’s ("adMarketplace’s") products and services
(“Service(s)”)
which is for the purpose of providing certain advertising related services for
our
Customers.
This Privacy Policy also informs about information collected from this website,
www.admarketplace.com, which serves two basic functions. First, it has
information about our Services as well as online advertising generally. Second,
it is a portal
for adMarketplace publishers and advertisers ("Customer(s)") to access certain
restricted,
Customer-only materials through secure log-in.
This Privacy Policy does not relate to Customer business information shared with
us (e.g.,
billing or contact details). As well, it does not relate to information shared
by employees or
other staff, or by applicants for positions with our company. You may reach your
business
or HR contact for inquiries related to such information).
1. OUR COMMITMENT TO DATA PRIVACY
It is of critical importance to us to keep the information we collect secure.
adMarketplace is
also committed to protecting the privacy of consumers and observes compliance
with
applicable laws, including the EU’s and United Kingdom’s Data Protection
Regulation
("GDPR") and various state privacy laws in the United States including CCPA (“US
Privacy
Laws”) and relevant laws of other countries and/or regions, collectively
referred to as
“Data Protection Laws”. As our practices evolve, this Privacy Policy may be
revised to
reflect those changes. Notice of such amendments will be posted as an updated
notice on
this website. Please review this Privacy Policy periodically in order to keep up
to date with
any modifications.
2. WHO IS ADMARKETPLACE?
adMarketplace is a provider of Services that enable our Customers to reach
consumers as
they search for or indicate intent to learn more about or engage with our
Customers’
products or services. Our Services do not use Personal Information to track,
target, or
otherwise profile consumers across unrelated websites, apps, devices, platforms
or
properties (collectively referred to herein as ‘Sites’). Personal Information
(also referred to
as Personal Data) means any information related to an identifiable person and
includes IP
addresses, cookie identifiers and device identifiers.
(Personal Information is distinct from Personally Identifiable Information (PII)
which is
information that on its own is able to identify, contact, or locate an
individual. An example
of PII is an individual’s email address. adMarketplace Services do not collect,
process, or
use PII).
The corporate entity that decides how and for what purpose we process
information (the
legal basis for processing) is:
adMarketplace, Inc.,
90 Park Ave,
11th Floor New York, NY 10016 USA
Tel. +1 212 925 2022
Email: privacy@admarketplace.com
3. PURPOSES OF AND LEGAL BASES FOR PROCESSING OF PERSONAL INFORMATION
We process Personal Information as set out below:
a. If you are an internet user visiting one of our Customer’s Sites: On behalf
of our
Customer, we may process Personal Information in order to deliver ads to the
Site
you visit. To illustrate, our technology shows ads in the following ways:
* Pre-search: we show tiles (display ads) for different trusted brands who are
our
Customers, below the search box
* During search: while a search request is being typed, we may show links that
allow you to directly navigate to the brand Site(s) and "skip" having to go
to
a search engine results page
* Post-search: we may include links to brand Sites within search results
* Native Search: we may include links to brand Sites within editorial,
informational
or consumer-generated content
* Push Notifications: if you have expressly opted-in, we may show notifications
from brands at a specific time of day to your desktop, mobile or other device
* Auto-complete Search: we may provide auto-complete feature and/or redirect
your mistyped or misspelled brand searches to the actual brand domain you may
have intended to type, and thus bypass parked pages
b. We process Personal Information collected from our Customer’s Sites on their
behalf to deliver Services. Our bases for processing when you visit Customer
Sites is
as follows:
* For display of advertising: we are a processor or service provider to the
Publisher who has legitimate interest or obtained consent from you when you
visited their Site, to display advertising
* When a consumer clicks on an ad (creative) displayed on the site of our
publisher customer, we may operate as processor or service provider to the
advertiser whose ad (creative) the consumer chose to click
* In order to improve our Services and to develop new services or features for
our
Customers
* In order to maintain security, identify fraud and similar misconduct
* In order to understand trends in how users react to particular types of
advertisements or offers
* In order to provide insights and reporting back to Customers, such as
statistical
reporting in connection with the activity on Sites, optimization of the
location of
ad placement, ad performance, reach and frequency metrics, and billing
* In order to resolve or fix technical issues or problems and to respond to
user
inquiries and requests
* In order to comply with legal obligation - in some cases, we may have a legal
obligation to collect, maintain, or disclose personal information about you
in
relation to the Services
c. If you are a visitor to our Site (admarketplace.com): any processing of
Personal
Information is as follows:
* To process the information voluntarily shared with us when you contact us
(with inquiries, for example), and
* For operational purposes (relating to your device type, for example), to
enable,
improve, or otherwise manage the delivery of content on our Sites
4. WHAT ARE THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT FOR OUR SERVICES?
1. Search information such as commercial search terms (keywords) entered into a
search box
2. Online Identifiers, including browser and device information such as your
device’s
Internet protocol (“IP”) address, unique device identifiers such as
advertising,
hardware or operating system device identifiers (e.g., IDFA for iOS and AAID
for
Android), information about the type of Internet browser, and general
geographic
information, and in some cases, cookie IDs. Cookies are text files with a
small piece
of data sent from a website and stored in a user’s web browser or pixels
(graphics
embedded in ad content to reflect an interaction with an ad on a Customer’s
website
– pixels work similarly to cookies). You can find more information about
different
types of cookies at allaboutcookies.org
3. Commercial Information, including products and services you may have
interacted with on the Sites of our Customers
4. Internet Activity, including information about your actions on the Sites of
our
Customers, such as information related to the Site you are viewing; visit
dates and
times; the website you came from before, and visited after you clicked on an
ad; ad
engagement data
5. Advertisement performance information for ads served, viewed or clicked on,
such as information about the type of ad, the online location where the ad
was
served, whether it was clicked on, and the products and offers viewed while
browsing or searching
6. Inferences drawn by us or our Customers (or partners of our Customers or who
work with us) such as age range, demographics, and product interests
As with any information we collect or process, we do not use any Personal
Information
collected or shared with us to track, target, or otherwise profile consumers
across
unrelated Sites.
5. WHAT ARE CATEGORIES OF PERSONAL INFORMATION COLLECTED OUR WEBSITE?
1. User Provided Information - on our website’s "contact us" pages, fields are
provided so that customers or others interested in our Services can input
contact
details. We collect this information so that we can respond to the
information sent to
us
2. Online Identifiers - in order to maintain and manage our website, we record
information such as IP addresses, page views and clicks, and cookies for
gathering
website statistics.
6. STATEMENT ABOUT SENSITIVE INFORMATION AND ABOUT DEIDENTIFIED INFORMATION
We do not collect any personal information defined as “sensitive personal
information”
under CCPA or US Privacy Laws, nor any “special categories” of personal data per
GDPR.
The Services are not intended to process personal information of children under
the age of
16 and we do not knowingly collect, sell, share, or process any personal
information from
children under the age of 16. If you, as a parent or guardian, believe that your
child under
the age of 16 has interacted with our Services and caused us to unknowingly
collect
their personal information, please contact us and we will use our best efforts
to identify
and remove their information to the extent it is in our records.
In addition to our personal information collection and processing, we may
collect, create,
process, disclose and store information that is not considered personal
information
because it is not identifiable to a particular individual, such as sets of
aggregate data,
metadata, and other generalized information about online browsing, usage and
interactions, as well as de-identified information that does not reveal your
identity. We do
not attempt to re-identify or associate such information to you, and we retain
the right to
use and disclose such information in any manner permitted by applicable law.
7. WHAT ARE THE SOURCES OF PERSONAL INFORMATION?
1. Information received through technologies: When you interact with or on our
Customer’s Sites, depending on the applicable laws in your location, we may
receive
the categories of information provided above, through technologies such as
APIs or
cookies
2. Information we receive from our Customers or their data providers: Our
Customers may supply us with personal information about consumers, to the
extent
they have confirmed that they have sufficient authority to provide this
information
to us, in order to deliver more relevant content, advertising, products or
services.
Such processing is subject to those Customers’ privacy policies and the
legal terms
under which they collected the relevant personal information
8. PERSONAL INFORMATION DISCLOSURES
When we disclose personal information, we disclose it to the following
categories of
recipients for the following business and commercial purposes:
1. to our Customers or their designated third-party representatives as part of
our Services
2. to technology, infrastructure, operations and other service providers to
help support
the infrastructure necessary to provide the Services
3. We may also disclose information about you:
1. if we are required to do so by law or legal process, including in response
to a valid
request from law enforcement authorities or other government officials
2. when we believe disclosure is necessary or appropriate to prevent physical
harm or
financial loss or in connection with an investigation of suspected or actual
illegal
activity
3. if necessary to protect our legal rights or the legal rights of another
individual or
entity
4. in connection with a corporate reorganization or a sale or transfer of all
or a portion
of our business or asset, or
5. to any other person with your consent to the disclosure.
SELLING AND SHARING PERSONAL INFORMATION
We do NOT “sell,” “share,” process or disclose your personal information for
targeted
advertising or otherwise as those terms are defined under applicable U.S.
Privacy Laws.
9. SECURITY
adMarketplace applies commercially reasonable physical, technical and
organizational
security measures to protect information from unauthorized access, corruption or
loss.
These include storing information in databases which are protected by security
measures
such as password protection, multi-factor authentication, and encryption using
Transport
Layer Security technology (TLS). However, no system can be completely secure,
and we
make no guarantees as to security of information transmitted through our
Services or our
own website (adMarketplace.com)
10. THIRD PARTIES WE WORK WITH
We may use processors or service providers for our business purposes (e.g. for
data storage
or fraud detection); when we do so, we obligate these services to comply with
our Privacy
and Security policy requirements and the Privacy Shield Principles for onward
data
transfers, including obligations to provide the same level of protection that we
afford for
transferred data.
The adMarketplace website may contain links to third party websites; please be
aware that
we do not endorse and are not responsible for the privacy practices of those
websites. If
you follow a link to those websites, you should read their privacy notice and
terms and
conditions to discern their practices.
11. INTERNATIONAL DATA TRANSFERS
For EU and UK data transfers to entities in countries that have not been deemed
to provide
an adequate level of protection by the European Commission, we use approved
contracts,
such as the EU Standard Contractual Clauses for the transfer of personal data to
Third
Countries pursuant to Regulation (EU) 2016/679 in accordance with Commission
Implementing Decision (EU) 2021/914 of 4 June 2021 and the United Kingdom’s
International Data Transfer Addendum to the EU Commission Standard Contractual
Clauses, in force 21 March 2022, as appropriate and additional safeguards where
required.
adMarketplace complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF),
the
UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. adMarketplace
has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy
Framework Principles (EU-U.S. DPF Principles) with regard to the processing of
personal
data received from the European Union in reliance on the EU-U.S. DPF and from
the
United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S.
DPF.
adMarketplace has certified to the U.S. Department of Commerce that it adheres
to the
Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with
regard
to the processing of personal data received from Switzerland in reliance on the
Swiss-U.S. DPF.
If there is any conflict between the terms in this privacy policy and the
EU-U.S. DPF Principles
and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn
more about the
Data Privacy Framework (DPF) program, and to view our certification, please
visit
https://www.dataprivacyframework.gov/.
In compliance with the EU-US DPF Principles, adMarketplace commits to resolve
complaints
about our collection or use of your personal information. EU or UK individuals
with questions
concerning our DPF policy may directed them to privacy@admarketplace.com. If we
have
not been able to satisfactorily resolve the issue, then, you may submit your
complaint to
JAMS using this link: https://www.jamsadr.com/eu-us-data-privacy-framework.
JAMS is adMarketplace’s designated DPF dispute resolution provider.
For transfers of personal data from non-EU/UK countries where international data
transfers are
limited or restricted, we comply with the relevant applicable laws to legitimize
such transfers.
adMarketplace is responsible for processing personal information it receives
under the DPF
and subsequently transfers to a third party acting as an agent on its behalf.
adMarketplace
shall remain liable under the Principles if its agent processes such personal
information in a
manner inconsistent with the Principles unless it shows it is not responsible
for the event
giving rise to the matter.
12. RETENTION OF DATA
We retain Personal Information for only as long as necessary for the business
purpose of
the processing. Personal Information collected by our Services is retained for
sixty-one days
in the normal course. Aggregated and anonymized may be retained for a longer
period for
statistical purposes and for reporting to and billing our customers.
13. YOUR PRIVACY RIGHTS UNDER DATA PROTECTION LAWS
Description of your privacy rights
You may have certain rights regarding your personal information, based on
applicable Data
Protection Laws, which may include the following:
1. To know about our processing of your personal information/data – you may
request
that we provide you:
2. Confirmation as to whether we are processing your personal information/data
3. The categories of personal information we process about you
4. The purposes of processing, including our business or commercial purpose
for
collecting, selling, or sharing your personal information
5. The categories of sources from which we collected your personal information
6. The categories of personal information we disclosed for a business purpose
and the
categories of recipients to whom we disclosed it, especially international
recipients
7. The categories of personal information we sold or shared with third parties
for
targeted or cross context behavioral advertising and the categories of
third parties
to whom we sold or shared it
8. The existence of any automated processing
9. Expected retention periods.
10. To Access your personal information/data portability – You may request that
we send
you (or another organization, under certain conditions) a copy of your
personal data in
our possession, in a readily usable and portable format.
11. To Rectify/Correct inaccurate personal information the information we hold
about you
– You may request that we correct personal information you believe is
inaccurate or
complete any information you believe is incomplete;
12. To Erase/Delete your personal information – You may request that we delete
your
personal information under certain conditions or subject to certain legal
exceptions;
13. To Restrict/Limit our processing of your personal information – You may
request that
we restrict our processing of your personal information, under certain
circumstances;
14. To Object to our Processing of your personal information – You may object
to our
processing of your personal information, under certain circumstances;
15. To Opt-out of certain disclosures of your personal information that may be
considered
selling or sharing for the purposes of targeted or cross-context behavioral
advertising;
16. To Withdraw your Consent – You may request to withdraw your consent for
processing
that is based on your consent;
17. To Not Be Subject to Discrimination for exercising your rights – We will
not discriminate
against you for exercising any of your privacy rights by denying you goods
or services,
charging you or suggesting you may receive different prices or rates for
goods or
services, or providing you a different level or quality of goods or
services if you exercise
your rights.
18. To Lodge a Complaint – We appreciate the opportunity to address any
complaint you
may have about our processing of your personal information or handling of
your rights
request, so please direct any concerns to us via email at
privacy@admarketplace.com.
Regardless, you have the right to complain to a data protection authority
about our
collection and use of your personal information. Contact details for data
protection
authorities in the European Economic Area are available here:
https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-be, and for
the
UK’s ICO here: https://ico.org.uk/global/contact-us/.
For Personal Information collected via our Services, you should contact the
relevant
Customer (Site publisher or advertiser) that is the business controlling or
controller of such
information.
In regard to Personal Information collected from our own website
(adMarketplace.com),
you can withdraw your consent by contacting us. In regard to Europe Data, you
may also
contact our DPO at dpo@admarketplace.com or privacy@admarketplace.com .
14. CALIFORNIA REQUIREMENTS
California residents have certain rights under the California Consumer Privacy
Act:
Click here to read additional disclosures required under CCPA.
Shine the light
California law permits California residents to annually request certain details
about how
their information is shared with third parties for their direct marketing
purposes. We do
not share your information with third parties for their direct marketing
purposes.
CHANGES TO THIS PRIVACY POLICY
adMarketplace reserves the right to change or replace this Privacy Policy at any
time to
reflect any changes in our privacy practices or updates to applicable laws. When
we update
our Privacy Policy, we will take appropriate measures to inform you, consistent
with the
significance of the changes we make. We will obtain your consent to any material
Privacy
Policy changes that affect your personal information if and where this is
required by
applicable data protection laws. Any changes or replacement will be posted on
our website
related to this Privacy Policy and located here. We encourage you to review our
Privacy Policy
on a regular basis.
CONTACT US
For any questions about our privacy practices, you may contact our data
protection officer
and privacy team by email here: privacy@admarketplace.com, or via:
Our postal address:
adMarketplace Inc.
90 Park Ave,
New York, NY 10016 USA
Tel. +1 212 925 2022
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