The Right to Privacy in the AdTrader advertising platforms
AdTrader enables advertisers to bid in real-time to gain the right to place advertisements via the AdTrader Platform ("the Platform") on one or more sites belonging to publishers as well as third-party websites and apps via numerous platforms and exchanges. The Platform runs on software developed and hosted by AdTrader, its subsidiaries, regional partners, and third-party contractors.
For the purposes of GDPR, AdTrader is the controller of your personal information, unless you are explicitly told otherwise.
We collect personal information directly from individuals, from third parties, and also automatically through the use of our Site. You do not have to provide us with your personal information to access much of our Site. However, if you choose not to disclose certain information, we may not be able to provide certain Services to you.
Information collected directly
We may collect personal information about you (such as your name, address, and contact details) directly from you. For example, when you fill out a "Contact Us" or "Join" form; sign up for our newsletter; register for an account; respond to special offers or surveys; or otherwise provide us information through the Site. Generally, the information we collect includes your:
- Name, company name, company website, information about your site (for publishers).
- Email address, mailing and billing address, phone number, language, IP address.
- Other information related to your request or inquiry.
Some of that information may be displayed throughout the Platform and will therefore become available to our employees, contractors, partners, and subsidiaries. If you choose to provide us with personal information, you consent to the transfer to and storage of that information on servers located in the United States.
To improve the functionality of the Platform and to ensure independent third-party verification of some advertising products, AdTrader may collect information about your business from third parties and provide this information to third parties on your behalf. This information may include, but is not limited to, third-party counts of monthly page views, visitor and audience composition, and rankings in various indices. AdTrader may not provide you with the option to turn off the collection and presentation of this information. In addition, AdTrader may collect tax information, including Value Added Tax (VAT) or federal tax ID numbers regarding your activities with respect to the Platform.
Information collected from cookies
- Providing support and services.
- Responding to your requests.
- Analyzing and optimizing our Site.
- Personalizing your experience to better engage with you.
- Advertising AdTrader’s products and services on third-party websites.
- Sending client alerts and information we think may interest you.
- Complying with legal operations, for example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
- Performing our general business operations, accounting, record keeping, and legal functions.
1. They are used to inform the AdTrader Demand-Side Platform (DSP) whether or not an advertisement has been served to the same computer before, and if so, when the advertisement was served. These cookies are not used by AdTrader to create a profile of a user's behavior.
2. They are also used to facilitate retargeting, the process of serving an ad from a particular advertiser to a user, based on the fact that the user has previously visited the advertiser's website. Retargeting occurs within the confines of the specific user-to-advertiser relationship.
The unique user identification number carried through the cookie on the user’s machine is generally deleted after 90 days of user inactivity. Aggregated statistical information for advertising campaigns are retained as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The Platform does not use any Flash cookies / LSOs (we use HTTP / browser cookies only) and does not perform browser / device fingerprinting.
Deleting and blocking cookies
Most web browsers and advertising technologies offer a way of managing how your data is used and choices for opting out of certain types of advertising and marketing. Below are links to help you set your preferences.
Browser Opt-out Options
Users can disable the cookies from their browsers to prevent services from gathering data about their interests and browsing patterns. Please note that due to the common usage of cookies, disabling them may limit your access to a large number of websites. If you wish to opt-out of the networks and advertisers using AdTrader's technology, please visit the NAI Opt-out page via the link below:
Google, Inc. Opt-out Options
For opt-out options in Google, Inc., please refer to the Digital Advertising Alliance Consumer Choice opt-out page provided below. The Google Preferences Page allows users to control their Google ad preferences from their Google Account.
Google (www.google.com) operates the Google Display Network, a collection of over a million websites, videos, and mobile apps that partner with Google to show ads. Google also runs DoubleClick, a digital advertising platform that creates, transacts, and manages digital advertising for the world’s buyers, creators, and sellers. The DoubleClick platform includes the DoubleClick Advertising Exchange and DoubleClick Bid Manager. To learn more about how Google collects and uses information for online advertising, please visit: http://www.google.com/intl/en/privacy.html
Mobile Device Opt-out Options
Users may disable cookies in their mobile browser (typically under Tools-Options-Privacy, but this may vary between browser types and versions). The cookies are used for a variety of reasons, not just targeted advertising. Hence, disabling them may adversely impact your online experience. Please note that if you delete your cookies, change browsers, or use a different computer, you will need to opt-out again.
To opt-out on your mobile device, you will need to download the AppChoices mobile app. Please be advised that if you use the settings on your mobile device to reset the mobile operating system advertising ID, you will also need to reset the preferences you select in AppChoices.
PURPOSES AND LEGAL BASES OF USE
|Purpose of Processing /Legitimate Business Interests||Legal Bases of Processing (EU Users)*|
|Providing support and services, Responding to your requests.||
|Analytics and improvement.||
|Marketing and advertising.||
|Protect our rights and prevent misuse, comply with legal obligation.||
|General business operations.||
* For the personal data from the EU that we process, this column describes the relevant legal bases for such processing under GDPR (and local implementing laws of EU member states); this does not limit or modify the obligations, rights, and requirements under the privacy laws of non-EU jurisdictions.
** For the personal data from the EU, the processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. Our legitimate interests include assessing and improving our products and services; understanding our clients’ needs and interests so that we can make our services more useful to clients; providing clients with news, information, and marketing materials that are more relevant; providing training opportunities for employees; improving how we analyze and assess the success of client campaigns; developing trend and benchmark reports; and similar purposes.
USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION
We do not sell your personal information to third parties. AdTrader collects personal information to provide users with a pleasant, relevant, efficient, and customized experience. We also strive to offer advertisers relevant actionable information about audience segments which might be interested in seeing their advertisements. During this process:
1. We may share information about publisher websites, including but not limited to page impressions and site traffic with advertisers. We will not share publisher personally identifiable information with advertisers at any time. Further, we may disclose publisher contact information and email address to third-party networks and exchanges that sell advertising on our behalf.
2. AdTrader may disclose personal information if required to do so by law or if AdTrader deems such disclosure necessary to protect and/or defend the rights and interests of AdTrader.
3. AdTrader from time to time may use contractors and vendors to help with some of our operations. Such third-party providers may have access to our databases with client information on a temporary basis for specific tasks. Such parties will only have access to information strictly required for the delivery of their services.
4. In the event that AdTrader is merged or acquired by another entity, personally identifiable information may be transferred to such entity as a part of the merger or acquisition.
AdTrader has operations in the United States, the EEA, and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EEA; you may request such details by contacting us at email@example.com.
YOUR CHOICES AND RIGHTS
Access, Amend and Correct. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, to request deletion of or object to processing of your information, please send your request to firstname.lastname@example.org. We may ask you for additional information so that we can confirm your identity.
Direct Marketing. You may always opt-out of direct marketing emails from us by following the instructions in such emails or emailing email@example.com. We may continue to send you transactional or service-related communications, such as service announcements, administrative messages, and invoices.
Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.
Users in the European Economic Area
Individuals in the EEA have the following rights with respect to their personal data:
1. Access. You can ask us to: confirm whether we are processing your personal data; give you a copy of that data; provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any profiling, to the extent that such information has not already been provided to you in this Policy.
2. Rectification. You can ask us to rectify inaccurate information. We may seek to verify the accuracy of the data before rectifying it.
3. Erasure. You can ask us to erase your personal data, but only where:
- it is no longer needed for the purposes for which it was collected;
- you have withdrawn your consent (where the data processing was based on consent);
- following a successful right to object (see "Objection" below);
- it has been processed unlawfully;
- or to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
- for compliance with a legal obligation;
- or for the establishment, exercise, or defense of legal claims.
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
4. Restriction. You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
- its accuracy is contested (see "Rectification" above), to allow us to verify its accuracy;
- the processing is unlawful, but you do not want it erased;
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend legal claims;
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
5. Right to object. You can ask us to stop processing your personal information, and we will do so (i) to the extent that we are relying on our legitimate interests to use your personal information, you have the right to object to such use, unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights, and freedoms or where we need to process the data for the establishment, exercise or defense of legal claims, and (ii) where we are processing your personal information for direct marketing purposes.
6. Portability. You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it "ported" directly to another Data Controller, but only where our processing is based on your consent and the processing is carried out by automated means.
7. Withdrawal of Consent. You can withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided.
AdTrader follows generally accepted industry standards to protect any sensitive information submitted to us. However, no data security measures can guarantee 100% security. If you have any questions or concerns about security on our website, please contact us at firstname.lastname@example.org. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court orders, or legal process.
All information we collect is stored in our servers located in the United States and the EU. To prevent unauthorized access, maintain accuracy of information, and ensure the appropriate use of information, AdTrader has put in place physical, electronic, and managerial procedures to safeguard and secure the information it collects online.
Your password is the key to your account in the AdTrader Advertising Platform. Please use unique numbers, letters, and special characters, and do not disclose your password to anyone, even an AdTrader representative. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password and/or notify AdTrader.
As a general rule, we retain your personal information for as long as necessary to fulfil the purposes for which it was collected, or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. In general, for example, we will retain relevant personal information of site visitors for 90 days from the date of our last interaction with you and in compliance with our obligations under applicable laws. Our clients instruct us on how long to retain Client Data, which we handle as a data processor. We may retain personal data for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.
INFORMATION ABOUT CHILDREN
The AdTrader site is not intended for minors under the age of 16. We do not knowingly or specifically collect information about minors under the age of 16. If you believe we have unintentionally collected such information, please notify us at email@example.com, so that we can delete this information from our servers.
If you have questions or concerns regarding the way in which your personal data is being processed or this Policy, please contact AdTrader at firstname.lastname@example.org.