Effective date: January 25, 2020
Thanks for entrusting Ad360 (“Ad360”, “Adventure Media”, “we”) with your information. Holding on to your private information is a serious responsibility, and we want you to know how we're handling it. We work hard to protect the safety and privacy of your information, and want to explain in more detail how we do it to put you in control.
The controller responsible for the processing of your personal information in connection with the Service is Adventure Media SARL, 76 rue de la pompe, Paris 75116, France, firstname.lastname@example.org.
Ad360 provides a digital advertising (or media buying) platform and technologies. The Ad360 platform helps advertisers buy advertising space on digital properties such as websites and mobile applications to distribute their ads. Ad360 provides tools to manage and buy data that can be used to personalise advertisements more and make sure they are shown to users who will find them more relevant. Ad360 also provides a technology that helps advertisers server, or deliver, their advertisement to a website or mobile application. The Service also comprises other tools, such as ad measurement tools and reports, ad effectiveness tools and reports, ad reach prediction tools and reports, and tools to prevent fraudulent activities and malware.
To perform the Service, Ad360 collects some information from users exposed to its technologies or advertisements. We take data privacy extremely seriously and only collect information that is relevant to help us operate, analyse or enhance the quality of the Service to our customers. You will find below sections that explain in more detail what information Ad360 collects, how we collect it, and for what purpose. You will also find more information and methods to opt-out of data collection.
Advertising is what makes many websites free of charge and is one of the backbone of the internet. Without advertising, the internet wouldn’t have progressed as rapidly as it did. Many of your favorite content and services online are made possible thanks to advertising.
To function properly, advertising requires a certain amount of data about the websites or mobile app where the advertisements are displayed, as well as data about the audience watching the ads. Indeed, most internet users prefer to watch ads that will be relevant to them. Ads are more pleasant and useful if they are related to your interests and needs. To be able to relate the proper ads to you and make this experience as relevant as possible, we need to collect some information about the users, such as their interests. This data is collected through your responses to ads that are shown to you, such as clicks on display banners or video skipped. This ensures we can deliver ads that you would rather see.
We work hard to make sure that our data collection and ads we deliver are safe, unobtrusive and as relevant as possible to you. To ensure that, we adhere to the high standards in terms of privacy, which are set forth below.
"User Personal Information" is any information about a user exposed to one of our advertisements or technologies which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as an Internet protocol (IP) address are examples of “User Personal Information.”
User Personal Information does not include aggregated, non-personally identifying information that does not identify a user or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, non-personally identifying information for research purposes and to operate, analyze, improve, and optimize our Website and Service.
If you're accessing our Service or Website, we automatically collect the same basic information that most services collect, subject, where necessary, to your consent. This includes information about how you use the Service, such as the pages you view, the referring site, your IP address and session information, and the date and time of each request. This is information we collect from every visitor to the Website. This information may include User Personal information.
As further described in our Cookies Policy, and subject, where applicable, to your consent, we automatically collect information from cookies and similar technologies (such as cookie ID and settings).
Some of the cookies are used to personalise advertisements shown to you. You will find more information in the Advertising section of our Cookies Policy.
To opt-out of cookies and know how to turn off cookies, please refer to the “How do I turn off cookies?” section of our Cookies Policy.
We may collect certain information about your device, such as its IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer. This information may include User Personal information.
Ad360 may collect User Personal Information from third parties. For example, this may happen if you are exposed to our advertisements or technologies through the website, app or technology from one of our vendors, partners, or affiliates.
We may assign a unique identifier called an Ad360 ID to your browser, your devices, such as your mobile device, connected device, or other screens you may encounter when we serve an ad to it or when you use it to access a client’s digital properties. Digital Properties include websites, emails, apps ("Digital Properties"). The Ad360 ID enables our advertising product and technologies to determine that a browser or device is probably the same as one that has already previously interacted with Ad360. In some cases, based on data we receive from our clients or partners, we are able to infer within a reasonable probability that a particular browser or device should be associated with the same Ad360 ID.
Although we do not collect Sensitive Personal Data (for more information, see section below: What information Ad360 does not collect), there is some information received from partner advertising-related products, technologies or services which will be tied to your Ad360 ID:
Ad360 may receive personal data about you when we have the opportunity to show you an ad on Digital Properties and collects additional data when we deliver an ad. We refer to this data as Bid Request Data and Impression Data. The sources of Bid Request and Impression Data are your browser or device and media supply sources, such as publishers (i.e. organizations who operate Digital Properties) and exchanges or supply-side platforms who display ads on publishers' Digital Properties. This includes data that may be considered personal data in your jurisdiction such as your Internet Protocol (“IP”) address, imprecise location (e.g., country, region, postal or zip code), browser type (e.g., Chrome or Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); and Internet Service Provider (e.g., Comcast or Verizon). It also may include IDs that our partners assign to your browser or device.
Ad360 may create or receive data about groups of users that share a common attribute or attributes, which is called a Segment data. Ad360 does not knowingly create segments that are based upon what can be considere sensitive information (e.g. for EEA users, no segments contain data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, personal data concerning your health, sex life or sexual orientation, or genetic or biometric data). Our clients may use the Service to process some sensitive data (but excluding sensitive categories in the EEA), which may come from our clients’ Digital Properties or our partners. Ad360 may process segments based on demographic information such as race, gender and income range where such information is not considered sensitive. We take steps designed to ensure that this is done in compliance with applicable laws and self-regulatory guidelines, including through our contracts and policies with our clients and partners, but our clients are responsible for this processing, and any queries should be directed to them.
Ad360 uses proprietary algorithms and partner’s technology, including technology that can be referred to as “Artificial Intelligence”, to make decisions about how to respond to Bid requests and which advertisements should be delivered for a user. The ways in which we use algorithms to determine when, how and how much to bid may be considered automated decision-making in some jurisdictions. Additionally, these processes, in combination with segments creation or campaigns audience targeting settings, may constitute profiling in some jurisdictions. This data is linked to a Ad360 ID, which is anonymised, and we only use these technologies and data to enhance the relevance of advertisements for users and the efficiency of campaigns for advertisers. We do not knowingly process or make automated decisions about EEA users based on any data that falls into special categories of sensitive personal data in the EEA.
We do not intentionally collect “Sensitive Personal Information”, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Ad360 does not knowingly collect information from or direct any of our content specifically to children under 13.
'Cookies' are small text files that are stored by the browser (e.g. Chrome, Firefox, Internet Explorer or Safari) on your computer or mobile phone. They allow websites to store things like user preferences. You can think of cookies as providing a 'memory' for the website, so that it can recognise you when you come back and respond appropriately. Pixels and tagging scripts are elements of the website or app that allow communication between your browser and our servers. A pixel is a small transparent image that is placed on a web page. A tagging script is a small piece of website code that is run by the web browser. We may also receive Information from our partners and clients via server-to-server connection, or via secure file transfer.
We use a number of third-party analytics and service providers to help us evaluate the use of our website, compile statistical reports on activity, and improve our content and Website performance. We only use these third-party analytics providers on certain areas of our Website, and all of them have signed data protection agreements with us that limit the type of User Personal Information they can collect and the purpose for which they can process the information. In addition, we use our own internal analytics software to provide features and improve our content and performance.
Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Ad360 responds to browser DNT signals and follows the W3C standard for responding to DNT signals. If you have not enabled DNT on a browser that supports it, cookies on some parts of our Website will track your online browsing activity on other online services over time.
To the extent that our processing of your User Personal Information is subject to certain international laws (including, but not limited to, the European Union's General Data Protection Regulation (GDPR)), Ad360 is required to notify you about the legal basis on which we process User Personal Information. Ad360 processes User Personal Information on the following legal bases:
If you would like to request deletion of data we process on the basis of consent or if you object to our processing of personal information, please use our Contact form.
We may share your User Personal Information with third parties under one of the following circumstances:
We share User Personal Information with a limited number of service providers who process it on our behalf to provide or improve our Service, and who have agreed to privacy restrictions similar to the ones in our Privacy Statement by signing data protection agreements or making similar commitments. Our service providers perform network data transmission, advertisements verification, advertisements delivery, and other similar services.
Ad360 strives for transparency in complying with legal process and legal obligations. Unless prevented from doing so by law or court order, or in rare, exigent circumstances, we make a reasonable effort to notify users of any legally compelled or required disclosure of their information. Ad360 may disclose User Personal Information or other information we collect about you to law enforcement if required in response to a valid subpoena, court order, search warrant, a similar government order, or when we believe in good faith that disclosure is necessary to comply with our legal obligations, to protect our property or rights, or those of third parties or the public at large.
We may share User Personal Information if we are involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our Website or by email before any transfer of your User Personal Information.
We share certain aggregated, non-personally identifying information with others about how our users, collectively, respond to Ad360 advertising products and services.
We do not sell your User Personal Information for monetary or other consideration.
If Ad360 processes information about you, such as information Ad360 receives from third parties, then you may, subject to applicable law, access, update, alter, delete, or object to the processing of your personal information by contacting Ad360 Support.
To completely remove all cookies from your browser, please refer to the section How do I turn cookies off? in our Cookies Policy
Ad360 takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information.
Ad360 enforces a written security information program. Our program:
In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected Users without undue delay.
Transmission of data on Ad360 is encrypted using SSH, HTTPS (TLS).
No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
If you have concerns about the way Ad360 is handling your User Personal Information, please let us know immediately. We want to help. You may contact us by filling out the Contact form. You may also email us directly at email@example.com with the subject line "Privacy Concerns." We will respond promptly — within 45 days at the latest.
You may also contact our Data Protection Officer directly.
Adventure Media SARL
76 rue de la Pompe
In the unlikely event that a dispute arises between you and Ad360 regarding our handling of your User Personal Information, we will do our best to resolve it. If we cannot, we can use an Independent Arbitration or cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals, and with the Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving disputes with Swiss individuals. Please contact us if you’d like us to direct you to your data protection authority contacts.
Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority.
Questions regarding Ad360's Privacy Statement or information practices should be directed to our Contact form.