Effective Date: August 23, 2023
ADSGARD SP. Z O.O, along with its subsidiaries and affiliated entities (referred to as “Adsgard” “we,” “us,” or “our”), is committed to ensuring the proper security and utilization of your personal information (referred to as “Personal Information”). As an international digital marketing company, Adsgard offers a comprehensive array of digital and programmatic advertising solutions (referred to as the “Service”) to advertisers, agencies, publishers, and application developers (collectively referred to as “Customers”).
This document (referred to as the “Policy”) elucidates our approach to privacy concerning the processing of Personal Information within Adsgard’s advertising solutions and platforms, as well as on Adsgard’s official website (referred to as the “Site”). Your Personal Information is handled in accordance with the terms outlined in this Policy.
This Policy pertains to the information we might handle:
- Regarding visitors who access, utilize, or engage with the Site, as well as individuals who communicate with us for inquiries;
- Regarding Customers and personnel (including contractors or other points of contact) associated with our Customers;
- Regarding individuals who explore the websites and/or applications of our Customers (“End Users”). (collectively referred to as “you” or “users”).
1. THE SERVICES
Adsgard furnishes Customers with tailor-made digital and programmatic advertising solutions, bolstered by exclusive platforms and optimization technologies. Consequently, Adsgard maintains no direct interaction with individuals who frequent Customers’ websites and/or applications.
The Personal Information amassed by Adsgard is primarily employed in the context of Real-Time Bidding — a sophisticated technological framework allowing advertising purchasers to bid “in the moment” for the chance to display online advertisements whenever an End User accesses a webpage, app, or any other digital media source.
We gather data that you furnish to our Customers, in addition to information regarding your device, as elaborated upon in the Policy. In situations where we process Personal Information concerning End Users, obtained from our Customers through the provision of our Services, Adsgard functions as an independent controller of said Personal Information. Our Customers also assume the role of independent controllers for this Personal Information.
2. COLLECTION OF PERSONAL INFORMATION
Adsgard engages in the processing of personal data, which we obtain from our Customers, yourself, or a representative acting on your behalf (such as your employer) within the framework of our business operations. Additionally, as required to deliver our Service and adhere to our contractual, policy, and other commitments, we may process personal information obtained from publicly accessible sources.
The term “Personal Information” pertains to any information that identifies an individual or makes their identity discernible. This category does not encompass data that has been modified to remove identity details, referred to as “anonymous data.”
2.1. Visitors to Our Site and Individuals Contacting Us with Inquiries
We, or designated third parties acting on our behalf, gather and employ personal information that may encompass:
- Personal Information belonging to visitors of our Site, particularly when they establish communication or engage with the Site;
- Details pertaining to your queries and/or general aspects of your interest in our Service;
- First and last name, email address, contact number, or any other details shared by visitors during interactions conducted via email, facsimile, telephone, or alternate means.
Upon visiting our Site, our servers register specific “traffic/session” particulars originating from your device, such as your user agent and Internet Protocol (IP) address.
While utilizing our Site, we may amass information related to your activities, encompassing log-in and log-out times, session durations, accessed web pages, specific content within web pages, activity metrics, and the geographical location of your device.
The Site also incorporates links to third-party social media platforms such as Facebook®, Twitter®, LinkedIn®, accompanied by associated social media features and scripts, like the Facebook® “like” button and widgets. These elements and scripts are designed to collect your IP address, determine the page you are visiting on the Site, and establish a cookie to facilitate their proper functionality. Social media features and widgets are hosted either by the relevant third-party social media platforms or directly on the Site.
Your interactions with these social media features, widgets, and the social media platforms themselves are subject to the privacy policies of the respective social media sites. If you provide Personal Information in a comment on a blog post or on any related social media platform, it’s important to recognize that this information may be read, gathered, or used by others, potentially leading to unsolicited messages or unauthorized contact without your consent or intent.
It’s important to note that the submission of Personal Information in these forums is your responsibility, and we are not accountable for the Personal Information you choose to disclose.
During your interactions with us, whether initiated by you or by us, any Personal Information you provide will be received and processed.
In addition to other endorsements, we showcase personal testimonials from contented Customers on the Site. With your consent, we may publish your testimonial accompanied by your name. Should you wish to modify or remove your testimonial, please reach out to us at: email@example.com.
2.2. Customers and Personnel (Contractors or Other Contacts) of Our Customers (including Prospective Customers)
We, or authorized third parties on our behalf, gather and utilize personal information which may encompass:
- Your first and last name, contact number, company name, and email address for purposes related to Service registration and communication;
- Information you furnish when engaging with us via email, fax, telephone, or other means of communication with our customer service.
2.3. End Users
We, or designated third parties acting on our behalf, gather and utilize personal information which may include:
- Personal Information provided by the End User to our Customers, encompassing attributes like age or gender;
- Details concerning the End User’s device, comprising device specifications, model, manufacturer, operating system version, connection type, and device identifiers such as mobile advertising IDs (such as Apple’s iOS Identifier for Advertising or Google’s Android Advertising ID). This category also covers geographic location data if location services are enabled for an app integrated with our Service on the End User’s device, and the IP address used by the device to access a Customer’s website or app;
- Personal Information regarding the End User’s interactions on our Customers’ websites or apps, including data about activities, actions, and session commencement and conclusion times;
- Insights regarding advertisements served, viewed, or interacted with, such as ad type, placement, user interaction (clicks), frequency of exposure, and actions following exposure, such as visiting the Customer’s website or app store, purchasing products or services advertised, or installing advertised apps.
We employ digital identifiers to automatically gather specific information, some of which might identify a particular computer or device and may be considered Personal Information. This information is acquired through the use of digital identifiers. Additional details about our digital identifiers can be found below:
- Beacons, Pixels, and Tags: These elements facilitate data collection, advertising delivery, and related services like measurement or fraud prevention on websites. They enable communication between a web browser and a server and are implemented as small transparent images (beacons) or computer code segments (tags) that operate within a web browser.
- Mobile SDK: The mobile SDK, akin to beacons and tags, is a code embedded in mobile apps. It supports ad display and associated services such as measurement and fraud prevention by collecting and analyzing data accessible through the installed mobile SDK.
- Cookie: Cookies are modest text files retained in a web browser by websites or ad servers. They store information to facilitate preference retention or browser recognition between visits or across websites.
- Non-Cookie Technology: In a diverse online landscape with varied devices, software platforms, and services, cookies might not always be applicable. Consequently, alternative approaches, such as unique IDs provided by platforms like Apple’s iOS and Google’s Play Services for Android, are used for advertising distinction. Many mobile devices possess unique identifiers that can also serve as distinguishing marks. Furthermore, mathematical techniques can be employed to intelligently infer device recognition.
3. HOW WE UTILIZE PERSONAL INFORMATION AND THE LEGAL BASIS FOR SUCH USAGE
We gather, employ, and retain the aforementioned personal information for the subsequent purposes:
3.1. Providing the Service
In our provision of the Service to Customers, we may utilize Personal Information about End Users for the ensuing purposes:
- Serving Ads:
We gather Personal Information about End Users to enable our Publisher Customers to auction advertising inventory on their websites and/or apps and to populate this inventory with pertinent ads.
- Interest-Based Advertising:
Personal Information about End Users is collected to deliver targeted advertisements, grounded in the End Users’ online activities across websites and mobile applications, along with data about their inferred commercial interests.
- Ad Reporting and Conversions:
Information about End Users’ interactions is utilized to generate reports for our Advertising Customers, illustrating when and how End Users have encountered, interacted with, or acted upon ads.
Personal Information about End Users helps customize ads according to their current or previous geographical locations.
- Ad Measurement:
End User responses to ads, such as clicks, are analyzed to comprehend ad effectiveness.
- Aggregated Statistics:
End User data contributes to aggregated reports that offer insights into the efficacy of online advertising campaigns.
- Cross-Device Mapping:
We facilitate cross-device mapping to serve or assess advertising on interconnected devices for the benefit of our Customers.
- Fraud Detection and Prevention:
Personal Information aids in identifying and preventing invalid clicks or queries, safeguarding Customers from fraudulent activities.
- Security and Debugging:
End User Personal Information is employed to identify and rectify errors within our Service, ensuring proper and secure system operations.
- Frequency Capping:
Personal Information is leveraged to regulate the frequency at which End Users encounter the same ad across diverse websites and applications.
For users within the EEA or the United Kingdom, personalized ads require prior consent from publishers, allowing Adsgard and its Customers to process End Users’ Personal Information. Consent might also be sought from users outside of these regions. In the absence of consent for personalized advertising, Adsgard may still process Personal Information for certain non-personalized advertising purposes based on legitimate interest. This includes processing for activities like contextual advertisements, Frequency Capping, Fraud Detection and Prevention, and Security and Debug. Processing may also continue where it’s reasonably necessary to safeguard individuals’ rights, address fraud or security issues, or protect Adsgard’s rights or property.
3.2. Ensuring a Safe and Secure Environment:
Personal Information contributes to fraud detection, abuse prevention, and security incident identification. It verifies and authenticates user identities, prevents unauthorized or unlawful actions, and enhances Service safety. This data facilitates security investigations, risk assessments, and internal policy compliance, aiming to prevent breaches of terms of service or applicable laws.
3.3. Site Operation:
Personal Information is used to enable access and usage of our Site, receive inquiries, ensure Site security, and provide technical support and maintenance.
3.4. Contacting Our Customers:
Personal Information about our Customers and related personnel (including contractors or representatives) is used to facilitate the provision of our Service, fulfill due diligence requirements, meet contractual obligations, and adhere to internal policies. This information is also employed to maintain communication, send notifications, reminders, and information about the Service, and offer technical and professional support.
3.5. Improvement of Our Service and Site:
Personal Information aids in hosting, operating, securing, and enhancing our Service and Site. It enables tool and feature functionality, analysis of Service and Site functionality, and support provision. Additionally, this data helps evaluate Service activity for pricing purposes and supports ongoing Service and Site development.
3.6. Compliance with Legal Obligations:
Personal Information may be used to enforce terms, policies, and legal agreements, comply with court orders and law enforcement requests, and aid in debt collection, fraud prevention, and legal proceedings.
3.7. Business Administration:
This data serves internal corporate reporting, business administration, insurance and financing management, facility security, research and development, and business efficiency enhancements.
3.8. Sending Marketing and Promotional Communications:
Personal Information is collected to dispatch marketing and promotional communications according to user preferences, with an option to opt out at any time.
The processing of Personal Information for these purposes aligns with our legitimate interests and aims to enhance user experiences, provide relevant information, and improve the overall quality of our Service and Site.
4. AGGREGATED AND ANALYTICAL INFORMATION
We employ standard analytics tools, and the privacy practices of these tools adhere to their respective privacy policies. These tools utilize their own cookies to facilitate their services (for detailed information about cookies, refer to the ‘Cookies’ section within this Policy).
We utilize anonymous, statistical, or aggregated information and may share it with partners for legitimate business purposes. This practice does not compromise your privacy, as the aggregated data does not contain specifics that can be reasonably linked back to you or any individual.
You retain the option to opt out of our mailing lists and discontinue the use of our Service. If desired, you can request Adsgard to cease the collection of any personal information concerning you.
Please note that our Service does not acknowledge Do Not Track (DNT) signals. If you are a resident of California, you are entitled to exercise your California privacy rights.
5. SHARING PERSONAL INFORMATION WITH OTHERS
We may share your Personal Information with our Customers, service providers, and other third parties when it is necessary to fulfill the stated purposes of collecting such information.
Furthermore, we may disclose Personal Information to affiliated companies, organizations, or entities associated with us, such as subsidiaries, sister companies, and parent companies. This sharing occurs when it aligns with our legitimate interests for internal administrative functions, such as ensuring consistent and coordinated Service delivery, corporate strategy implementation, compliance adherence, auditing and monitoring, research and development, and quality assurance.
We might also reveal your Personal Information to third parties as part of our legitimate business interests, which include running, expanding, and enhancing our operations. This can include scenarios such as:
- In the event of a business sale or acquisition, we may share your personal information with prospective sellers or buyers of the business or assets.
- If we transfer substantially all of our assets to a third party, your personal information may be included among the assets transferred.
- When we are obligated to disclose your personal information to comply with legal requirements or to enforce our terms and conditions and other agreements. This could also involve protecting our rights, property, or safety, as well as those of our customers or others. Such disclosures may involve sharing information with other companies and organizations to combat fraud.
Please note that in these scenarios, we will exercise due diligence to ensure that any sharing of Personal Information is carried out in accordance with applicable laws and regulations.
6. YOUR CHOICE
You maintain control over your preferences and choices regarding the use of your Personal Information:
- Unsubscribing from Mailing Lists and Newsletters: You can opt out of receiving our mailing lists or newsletters by sending an opt-out request to: firstname.lastname@example.org.
- Disabling Your Account: You have the option to deactivate your account through your account page.
- Opt-Out Options: You can choose to object to the disclosure of your Personal Information to third parties, except for those acting as our agents to execute tasks on our behalf and under our guidance. Additionally, you can object to the utilization of your Personal Information for purposes significantly distinct from the original intentions for collecting the information as specified in this Policy, or purposes for which you subsequently granted authorization. You can exercise these choices by reaching out to us at: email@example.com.
- Data Collection and Retention: We collect only the minimal Personal Information required for the purposes outlined in this Policy. Following the conclusion or expiration of the Service, we will cease the collection of any Personal Information related to you. However, your Personal Information will be stored and utilized in accordance with our data retention section as detailed in this Policy.
- Do Not Track (DNT) Signals: While some web browsers offer a “Do Not Track” (DNT) signal, our Service does not respond to such signals.
- Opting Out of Interest-Based Advertising: If you wish to avoid interest-based advertising on behalf of Adsgard, you can opt out of data collection and targeted advertising services linked to our Service. It’s important to note that even after opting out, you might still receive content and advertising from us; however, this content and advertising will not be targeted or interest-based.
For instructions on how to opt out based on your device, please consult device-specific information:
Should you require further assistance, you can also contact us at firstname.lastname@example.org, and we will be pleased to aid you.
You may limit the disclosure of certain information by your mobile device to us and our Partners by adjusting the settings on your mobile device. For iOS mobile Devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile Devices, go to “Google Settings” on your Device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.”
Our Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to their privacy policies to learn more about the privacy practices of our Partners. Please note however, that we have no control and we are not responsible for the privacy practices of our Partners.
Adsgard Service is not intended for nor directed to individuals that are deemed to be children under applicable data protection or privacy laws (“children”), and we request that such children do not provide Personal Information through any of Adsgard’s Service. If you believe that Adsgard has inadvertently collected information from children in the course of the provision of the Service, please contact us at: email@example.com to request the deletion of the information.
7. ACCESSING YOUR PERSONAL INFORMATION
Should you discover that the information within your account is inaccurate, incomplete, or outdated, we welcome you to provide the necessary details for its correction.
You can contact us at any time via firstname.lastname@example.org to request access to the Personal Information we possess about you. To ensure security, we may require specific credentials to verify your identity. We will make sincere efforts to locate and provide the Personal Information you request, to the extent mandated by applicable law.
If you are entitled to the right of access under applicable law, you have the privilege to:
- Confirm the accuracy and lawfulness of the processing of your Personal Information.
- Request correction, amendment, or deletion of inaccurate Personal Information or data processed in violation of applicable law.
We will exercise prudence and diligence to redact Personal Information related to others from the data we disclose to you.
8. YOUR EU DATA SUBJECT RIGHTS
Notice to Residents of the EEA, Switzerland and UK: Data Subject Rights
Please note that if you are an EEA resident, the General Data Protection Regulation applies to the processing of your personal data. We adhere to the GDPR.
We also apply substantially the same standards of data protection to all of our users taking into account (if any) limitations, exemptions, or privileges imposed by your national law.
In certain jurisdictions, especially within the European Union (EU) or the European Economic Area (EEA), specific rights concerning your Personal Information may apply. Subject to eligibility, you might possess the subsequent rights:
Request the rectification of incorrect or incomplete Personal Information we hold about you.
Object to the processing of your Personal Information for direct marketing purposes.
Object to the processing of your Personal Information when the legal basis for such processing is our legitimate interests.
Object to automated decision-making (including profiling) under specific conditions.
Request the erasure of your Personal Information under certain circumstances, such as when processing is no longer necessary or lawful.
Receive your Personal Information or ask us to transfer it to another organization, where such processing is based on consent or a contract.
Lodge a complaint with the data protection supervisory authority in your habitual residence or workplace regarding a suspected violation of GDPR.
More details about your rights under EU data protection laws can be found on the EU Commission’s website: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
Please note that we will need to authenticate your identity and location when you submit a request to exercise your rights. To ensure your authenticity, we will request credentials and further information to understand your request’s nature and scope.
If we need to delete your personal data following your request, it may take some time to remove residual copies from our active servers and backup systems.
Should you harbor concerns about our processing of your personal data, feel free to contact us at email@example.com. We will promptly address your inquiry and respond in good faith.
9. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of California, you have certain rights under California Civil Code Section 1798.83. This code enables you to request, in writing, a list of the categories of personally identifiable information that we have shared with third parties for their direct marketing purposes during the preceding year. To make such a request, please contact us at: firstname.lastname@example.org
- Accessing Your Personally Identifiable Information
Should you find that the information in your account is inaccurate, incomplete, or outdated, we encourage you to provide us with the necessary details to rectify it. You can contact us at any time via email@example.com to request access to the personally identifiable information we hold about you. To verify your identity, we may request specific credentials. In compliance with applicable law, we will earnestly attempt to locate and provide the personally identifiable information you request.
- California Online Privacy Protection Act
In line with CalOPPA, we adhere to the following:
- You can rectify your Personal Information by contacting us via email.
10. CAN SPAM Act
The CAN-SPAM Act is a US federal law that sets regulations for commercial email, mandates requirements for commercial messages, empowers recipients to cease receiving emails, and outlines severe penalties for violations.
To adhere to the CAN-SPAM Act, we commit to:
- Abstain from using false or misleading subjects or email addresses.
- Identify commercial messages as advertisements when necessary.
- Include our business or site headquarters’ physical address.
- Supervise third-party email marketing services for compliance, if utilized.
- Respect opt-out/unsubscribe requests promptly.
- Facilitate user unsubscribes through the link at the bottom of each email.
If you wish to unsubscribe from receiving future emails, you can email us at firstname.lastname@example.org, and we will promptly remove you from ALL correspondence.
11. DATA RETENTION
Our data retention periods vary depending on the type of Personal Information and the purposes for processing, in alignment with our legitimate business interests and legal requirements as stipulated by the applicable law.
Certain information, such as tax-related data, records for accounts settling, archiving, and legal matters, may need to be retained for several years to meet legal obligations. We will maintain your contact details to facilitate ongoing communication. Should you wish to have your contact details deleted, you can reach out to us at any point, either before or after terminating your account, by contacting us at: email@example.com. Please note that while we will retain your details for legal purposes, we will only use them when necessary.
Aggregated, non-identifiable information will be retained, and we will make reasonable efforts to either delete or de-identify potentially identifiable information when it is no longer required for processing.
For Customers, we will retain your information for as long as you utilize our Service, unless legal requirements dictate deletion or if we opt to remove it at our discretion in accordance with the terms of this Policy.
The storage and processing of information will occur across various locations worldwide, including those operated and maintained by cloud-based service providers.
12. TRANSFER OF DATA OUTSIDE YOUR TERRITORY
We will store and process information across different global sites, primarily within the EU. In compliance with EU privacy laws and regulations, we will implement appropriate data transfer mechanisms, including Standard Contractual Clauses and other lawful instruments available as needed, for transferring Personal Information.
Cookies are employed to streamline log-in processes and facilitate Service activities.
13. CCPA PRIVACY NOTICE
If you are a California resident this CCPA Privacy Notice is applicable to Personal Information that we may process about you.
Collection, Disclosure or Sale of Personal Information
Categories of Personal Information We Collect
- Internet or other electronic network activity information (such as browsing history, interactions with a website or advertisement).
- Geolocation information.
- Inferences drawn from the above information about your predicted characteristics and preferences.
- Other information about you that is linked to the personal information above.
Such Personal Information was received from the categories of sources of information set forth below, was collected for all of the purposes set forth below and was sold, used or shared to the third parties listed below:
- Categories of Sources: We collect this personal information from the following categories of sources: Publishers; Demand Partners; service providers (e.g. fraud prevention services, identity resolution platforms, Vendors on our website).
- Recipients of California Personal Information: To the extent our use of Personal Information constitutes a “Sale” under the CCPA, we “sell” Personal Information to the following categories of third parties: (i) DSPs and other demand partners (including, without limitation, demand-side platforms, ad agencies and advertisers), (ii) publishers and other supply partners, and (iii) advertising technology companies (including, without limitation, data management platforms used by our partners). We disclose (or might disclose) the categories of Personal Information designated above to the following categories of third parties, for the above commercial and business purposes: Service providers (as defined by the CCPA), government entities (upon request and to the extent we are obligated to do so), advertisers, publishers, other demand and supply partners, internet and other services providers such as fraud protection vendors and data analytics companies.
Your Rights Regarding Personal Information
If you are a California resident, you may exercise the following rights regarding your Personal Information, subject to certain exceptions and limitations: (i) the right to know categories and specific Personal Information we collect, use, disclose, and sell about you over the past twelve (12) months, categories of sources from which we collected your Personal Information, our purposes for collecting or selling your Personal Information, the categories of your Personal Information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared Personal Information, (ii) the right to request that we delete the Personal Information we have collected from you or maintain about you, (iii) the right to opt out of any “sale” of your Personal Information and (iv) the right not to be discriminated against for exercising any of your rights under the CCPA.
To exercise any of the above rights, please contact us at: firstname.lastname@example.org
Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you need to provide us with some additional information to enable us to identify the Personal Information we hold about you, if any, and ensure that we accurately fulfil your request.
Minors under 16
Without derogating from any of our statements above, we do not sell the personal information of consumers that we know to be under 16 years of age.
Contact us at: email@example.com or write us for every request and complaint. We will make good-faith efforts to resolve any existing or potential dispute with you.
15. DISPUTE RESOLUTION
We conduct regular evaluations of our data processing and privacy practices to ensure compliance with this Policy. We also perform updates to the Policy as deemed necessary and make sure it is displayed appropriately and accessibly. If you have concerns regarding our handling of your Personal Information, you are encouraged to reach out to us at: firstname.lastname@example.org or by writing to us. Our official address is available on our website: https://adsgard.net/.
Rest assured, we will thoroughly examine your concerns and make genuine efforts to resolve any existing or potential disputes with you.
Please note that we will provide proper notice when making updates to our Policy.
This Policy may be updated periodically. Minor updates, which have little or no impact, will come into effect 7 days after a notice is posted on the Service’s website. For substantial changes, the new Policy will be effective 15 days following the initial notice.
In the event that the new Policy significantly reduces the protection of your privacy rights compared to the existing policy, you have the option to decline it and discontinue your use of the Service. Should you continue to use the Service after the new Policy takes effect, it signifies your agreement with the updated terms.
Please be aware that if adjustments to the Policy are required to meet legal obligations, the new Policy will take effect immediately or as mandated by law.
How to contact us?
ADSGARD SP. Z O.O
str. Stanislawowska, nr 47, Wroclaw, Lower, Silesian Voivodeship, Poland 54-611