Notice at Collection

Personal information includes information that directly identifies you, such as your name and email address (“Personally Identifiable Information”), and information that can be associated with you or linked to you, including information about your browser or device (“Device Identified Information” or “Device Information”). All of this information together is considered “Personal Information” or “Personal Data.”

Personal Information We Collect

Ad.Tech is a new company. We do not disclose the information we have collected or shared over the past 12 months, as we have not been providing services for a full year. We currently collect the following personal information:

Mobile and other Platform identifiers.

We may collect identifiers or information about your visit to a media property through mobile identifiers, platform or operating system identifiers, or other unique identifiers that are not associated with browsers.

No Sensitive Information.

We do not collect any sensitive personal information about users. If we collect information from a web page that includes information about health conditions, including sensitive health conditions, we do not use the Device Information from that page to draw inferences about you or build profiles of you. We discard Device Information in accordance with our Data Retention Policies.

No Inferences or Profiles.

We do not use the information we collect to draw inferences about users or to create profiles based on their activities across unaffiliated websites over time.

No Information about Children.

Our services are intended for use by other businesses, and our website and services are not directed to children or used for advertising to children. We do not knowingly collect any personal information from children under 16.

Information you Provide.

When you contact us through our website or by email or phone to express interest in our products or services, to subscribe to our promotional or informational email messages, to communicate with us about an ongoing business relationship, or to tell us you would like to make choices about how we use your information, you provide us with your email address, and possibly your name and other contact information. You may also provide us with information about how you use, or would like to use, our services. When you interact with us, you may have the choice of whether to provide additional information about yourself, and tell us about your use of our products and services.

Information about Use of our Technology.

When our technology is used on a website or other media property, we receive information about how users engage with the content where our technology is used. We use this information only to provide services to our customers (websites or advertisers) and to improve our technology and services.

Information about Email Delivery.

We collect information about whether the email messages we send are opened.

How We Use Personal Information We Collect

We use your IP address to ensure the right ads are delivered to you and to determine your general geographic region. For example, this may allow us to determine your country, city, or the metropolitan area from which you are accessing the services. It does not tell us your precise location, and we do not try to derive this information in any other way.

We use the information we receive about your browser and the type of device and operating system you are using to communicate with advertisers and other partners about how best to deliver ads to you. We also use this information to help us analyze the way our services are accessed and used so that we may improve them.

We use cookie IDs or similar assigned identifiers that are placed on your browser or device by us, by websites that use our services, or by other partners to make sure the same device does not see the same advertisement too many times. We may also use cookie IDs to recognize your device or browser if you have visited our website, or the website of one of our content partners, before. We also use the information about your visits to web pages which we receive from cookies to help us understand how our services are used and improve our services.

We use click IDs to measure and report on the number of people who engage with advertising messages so that we and the advertiser can determine how effectively the advertisements communicate about the products they describe.

We use all of this information that does not directly identify you to analyze and report on the performance and effectiveness of our services and to improve our services.

When we license technology, we use the personal information we access to operate our technology or assist our licensees in using it, and to monitor the use of our technology.

We use the information you provide us through contact forms or by phone or email to respond to your requests, communicate with you about our products and services, and maintain business relationships.

We use information collected by Google Analytics on our behalf, and their analysis of that information, to better understand our customers’ use of our website and services and improve them.

We use information from surveys to develop and improve our business and our services.

Sources of Personal Information

We collect information from:

Your interaction with our website or the websites or search results pages where we provide advertising.

Cookies, pixels, web beacons and other such technologies that are used to identify a web browser or device and provide information about its interaction with websites and advertising.

Advertisers and their representatives provide us with information about their advertisements and the rates they are willing to pay to display them so that we can find the right context in which to deliver the ads (the right web pages or search results).

Websites send information through their business partners that tells us what kinds of ads they are interested in displaying and the rates they charge for the display of these ads.

When we license and operate our technology, we gather information by observation when we provide integration, maintenance, or other technical services.

Choices users make when they exercise their rights, such as whether to opt out of the sale or sharing of personal information, or opt out of targeted advertising, are passed to us from the websites you visit and through code that is attached to your browser.

Contact information is provided to us when you fill out a web form on our website, call us, or email us, or we may receive it in the course of ordinary business communications.

We receive contact information, other information you provide to us, and information about how you interact with a social media service such as LinkedIn, Twitter, Facebook or Instagram when you interact with our social media web pages.

We use clear gifs (web beacons) in email messages we send to determine whether you open them.

Cookies

Cookies are small pieces of code stored on your browser that can allow information about the web pages you have visited to be communicated by your browser. Some cookies are necessary to allow web pages to function. You can reject other cookies by changing the settings in your browser, however, this may limit the functionality of certain web pages and services, and it could mean that some of your choices, which may also be stored in cookies, will be lost.

Promotions or advertisements displayed via the services may also contain cookies, and we do not have access to or control over information collected by advertisers when you click on any such promotions or advertisements.

For more information about the cookies that appear on our website, and to exercise choices, please see our cookie policy, also accessible through the cookie choice banner that appears when you first visit our site in certain jurisdictions

Non-Cookie Identifiers (Mobile IDs)

Some technologies, platforms, or operating systems use their own IDs to collect and communicate information about users’ visits to their properties and engagement with their content and advertising. You cannot limit collection of information through these IDs, such as Apple IDFAs (IDs for Advertising) and Google Advertising IDS, in a browser setting. You must go to the settings on your device to make choices about whether these IDs are used to communicate information about you.

How and to Whom We Sell or Share Personal Information We Collect

We do not disclose personal information in exchange for money, but we may share it for other valuable consideration as part of the way we provide our services. Under some U.S. state laws, this may be considered a “sale” of personal information.

When you visit our website we disclose the information you provide us or that we collect from your browser or device to service providers who assist us in providing services. They are not permitted to use this personal information for other purposes. We also share this information with our analytics partners, including Google Analytics.

When we work with advertisers, we share information about the interaction of your browser or device with websites, search services, and advertisements with the advertisers who are our customers, and with their partners and representatives so that they can determine whether certain advertisements are likely to interest you and decide whether they want to present those ads to you. We also share this information with advertisers and their business partners to report on how we performed our services and to help with analysis of the effectiveness of their advertising.

When we work with advertisers and you visit other websites or use search services we work with, we may also share information we receive about your device and how it interacts with the website, or search results you are viewing, with the website or search services where advertisements using our services are shown for reporting and analysis of advertising performance. This reporting is done in aggregate form, describing how website visitors behaved as a group, not as a report on your individual activity.

When we work with advertisers we share some device information, such as cookies or similar IDs we obtain through tracking technologies, with advertisers and their business partners to help manage ad selection and delivery so that you see ads that make sense in the context where you are viewing them and do not see the same advertisement too many times, and to help us ensure we communicate accurate information about ad delivery to advertisers for their analysis of the effectiveness of their ads.

When we work with websites, we share information about the opportunity to present advertisements to users visiting their sites, along with the device information of those users, with advertisers and their partners and service providers in order to assist the websites in selling advertising opportunities on their websites. We only share this information when we are directed to do so by the websites who are our customers, and only for their benefit. We do not retain or use the personal information we share on their behalf for any other purpose.

When we provide technology services to websites that license our technology, we do not share any personal information we access in the course of providing those services.

The third parties, with which we share information, and the advertisers and websites that use our services, are required to disclose their own privacy and information practices through privacy notices on their own websites. Their information practices may be different from ours, but they must also honor privacy laws in the areas where they operate. We contractually require all of the parties with which we share information to have their own privacy policies. As we discuss below, if we receive notice of choices you make when you visit a website or otherwise, we will pass that information along to the third parties with which we share information, and will require them to honor certain choices also, such as your choice to opt out of sale or sharing.

We do not knowingly sell or share the personal information of children under 16.

We may disclose Personal Information if we determine that we are required to do so:

• To comply with applicable laws, or with legal process served on us;
• To protect or defend our rights or the rights of any of our users or business partners;
• To enforce our terms of use or other agreements; or
• To protect anyone’s rights, property or safety (including our own).

Social Media

We may maintain a presence on some social media services where you can learn about us and communicate with us about our services. We collect the same kinds of information from these social media pages that we collect from our own website. In addition, you may share information about your visits to our websites and your use of our services with social media services if you are logged into them.

Google Analytics

We use Google Analytics for site analysis. For more information about Google Analytics go to http://www.google.com/policies/privacy/partners (“How Google uses data when you use our partners’ sites or apps”). Users who don’t want their data collected and disclosed to Google Analytics can install the Google Analytics opt-out browser add-on. To opt out of Google Analytics, go to https://tools.google.com/dlpage/gaoptout .

Your Rights and Choices

Depending on where you live and where you access our services, you may have the right to request that we:

• provide you information about how we use your personal information;
• give you access to, and a copy of, your personal information that we store on our system;
• update, correct or delete your information held in our files;
• stop using, and require that third parties stop using, some or all of your personal information for certain purposes, even if you continue to use our site or services; and
• discontinue contacting you by phone or by email.

You may exercise these rights by submitting a privacy rights request here or by emailing us at privacy@advertising.tech or through the webform on the page that describes rights for a U.S. state.

Consumers from certain U.S. states have specific rights and choices available to them. You can get more information about these state specific rights, and exercise your choices, here.

Additional rights for certain international users are described here.

Universal Opt-Out Signals

We honor “Global Privacy Controls” or other universal opt out signals you can set in some browsers where we are required to do so by applicable law. These are signals you can send from your browser to a website to convey your choice to exercise certain opt-out rights granted by individual states.

Do Not Track

We do not honor Do Not Track signals sent by browsers that do not meet the requirements of universal opt out signals or global privacy controls under applicable law.

Data Retention Practices

We retain your personal information only for as long as we need it.

We retain information we receive from advertisers, websites, and their representatives and from business partners for up to a year after we end our business relationships with them, unless we have a valid legal reason to retain it longer.

We retain cookie information and other information associated with advertising IDs for no more than 60 days.

We truncate IP addresses soon after we collect them where required by applicable law. We retain IP addresses we log and other device information for no more than 180 days.

We retain aggregated information for reporting and analysis for 2 years, unless we are legally or contractually required to keep it longer.

We retain personally identifiable information you provide through business communications as long as our business relationship continues, and in some cases longer if we need to retain it to exercise our legal rights or defend legal claims.

We retain information from surveys for two years, in aggregate form.

Data Security

No information security is perfect, but we use commercially reasonable efforts and rely on technical and operational measures common in our industry to protect personal information and keep it secure. These methods may include encryption, limiting access to personal information to those who need to know it, and limiting how long we retain information.

We expect the services to include features that will help us track down bugs and crashes; some of these features will include reports that are generated by our users’ devices, and these reports include information about device type, capabilities, and other software running at the time of the crash. You will have the option whether or not to provide this information to us, and it will always be provided to us anonymously. This information will never include Personal Information and never be identifiable by user, and we will use this information for our development, debugging and other quality improvement efforts.

Protections for Children’s Privacy

Our services are primarily intended for use by other businesses, and our website and services are not directed to children or used for advertising to children. We do not knowingly collect, use, sell or share any personal information of children under 16.

International Users

Our services are provided in, and are directed at, users from the United States. Information we maintain may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we will process your information to the United States, which may not provide the same level of protection for your personal data as the laws of other countries.  When another company transfers personal data to us from the European Union, we agree to protect it as if it were protected under the General Data Protection Regulation (GDPR). International users should know that the controller of the Advertising.Tech website is Advertising.Tech Ltd and/or Advertising.Tech FZ-LLC.

Additional EU/UK Disclosures

Data controller. We are a data controller of all Personal Information collected through our website. If you have a complaint, contact our privacy officer using the information listed in the section titled “Contact Us” below. You may also report any concerns to the Data Protection Authority in your country.

Our Role and Legal Basis for our Processing of Personal Information. We act as a controller for our website, for our own business operations, and for some services we provide to advertisers, for example when we serve as a Demand Side Platform. For other services we provide, including to websites, we serve as a processor.

We process personal information when it is in our legitimate interest to do so (if we believe that our interests are not outweighed by the risks to data subjects), when we obtain data subjects’ consent for us to process the personal information, when we must process the personal information to perform our obligations under a contract (or in anticipation of a contract), or because we have a legal or regulatory right or obligation to do so. When we process personal information of website users, or place cookies on a user’s device, we rely on the consent that we or the website on which our technology is used has obtained. We rely on our legitimate interest when we use the personal information we are processing to prevent ads from being shown to a user too often, to detect fraud, and to improve our products or services. We believe the benefits of these additional uses are significant and there are few, if any, additional risks to data subjects. We rely on our legitimate interest to process certain business or employment information.

When we perform services for websites and provide technology implementation services, we generally act as a processor, and we rely on the controller for which we are providing services to have a valid legal basis for processing and instruct us to process the personal information on that basis.

Additional EU/UK Privacy Rights. If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. You have the right to request that we correct or erase your personal information. You also have the right to object to certain processing of your personal information and the right to obtain human review of any automated decision-making with significant or legal effects. You can exercise your rights at any time by submitting a privacy rights request here or by contacting us at privacy@advertising.tech.

Changes to this Policy

We may revise this policy from time to time – e.g., to keep up with changes in the law, or to reflect changes in how we are doing business. All services that are governed by this policy will always include our most up-to-date privacy policy, and we include an effective date at the top of the policy, so you can quickly see when we last updated the policy. We will always include links to previous policies so that you can compare them. Any updates or modifications to this privacy policy will be effective as soon as we post the updated privacy policy to the services unless we say otherwise, and it is your responsibility to review this privacy policy periodically to make sure you continue to be in agreement with all of its terms.

Material changes to this policy will not apply to information we have already collected unless we receive your consent for them to do so.

Contact Us

We welcome comments and questions on this policy, our information practices generally, or any related issues. You may use a message form that you can complete in order to contact us directly from the website. You can also contact us through any social media pages we maintain, as well as other business networking platforms. If you communicate with us by email, even if you have not previously provided us with your email address, we will use your email address if necessary, in order to respond to you, and we may retain your email address in our files during and for a period after the time that we are in communication.

You can reach us by postal or electronic mail at:

You can communicate about this privacy policy by emailing privacy@advertising.tech.

U.S. State Privacy Rights and Choices.

If you are a California consumer, you have the right to:

• know what information we have collected about you, ask us to delete your personal information;
• ask us to delete your personal information;
• ask us to correct personal information if you believe we are keeping inaccurate information about you; and
• opt-out of the sale or sharing of your personal information, including by sending a GPC signal from your browser.

We will not discriminate against you in any way for exercising these rights.

You can exercise these rights by emailing us at privacy@advertising.tech or you can make your request here. If you have a business account with us, we may use information in that account to authenticate you.

For certain requests (requests to know or correct the information we maintain about you) we may email you to confirm your identity. If we cannot confirm your identity for a request to delete information, we will treat it as a request to opt out of sale and sharing. An authorized agent may make requests on your behalf, but we will request proof that you gave permission for that agent to act for you. Agents who are making a request should do so by email.

If you are a Virginia, Connecticut, Colorado, Oregon, Texas, or Utah consumer, (or, beginning in October 2024, a Montana consumer), you have the right to:

• Confirm whether or not we are processing your personal information and access your personal information;
• Correct inaccuracies in your personal data and the purposes for which we are processing it;
• Delete your personal information;
• Obtain a copy of personal data you have previously provided to us, or in some states, all the personal data we have obtained about you, in a form that allows it to be shared with another controller;
• Opt out of targeted advertising;
• Opt out of the sale of your personal information;
• Opt out of profiling that would be used for significant decisions about you.
• If and when global privacy controls or other universal opt-out mechanisms are approved and honoring them is required in your state, you will also have the right to opt-out of sale, targeting, or profiling, or all of these, using these browser-based controls.

For certain requests, we may email you to confirm your identity. You can email us at privacy@advertising.tech or make your request here.