Privacy Statement
Effective : February 15th, 2024
1. Information About Us
Our site adtelligent.com (also “Our Site”) and all adtelligent.com subdomains are owned and operated by Adtelligent Inc., is an US corporation headquartered in United States, Delaware, 16192 Costal Hwy, City of Lewes, County of Sussex, 19958 (also referred to as “Adtelligent”, “we”, “our”, “us” etc.).
Adtelligent 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 Adtelligent 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. Adtelligent 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-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Adtelligent commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, and UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Adtelligent at:
- Adtelligent Inc., is an US corporation headquartered in United States, Delaware, 16192 Costal Hwy, City of Lewes, County of Sussex, 19958
- our data protection officer via legal@adtelligent.com
If there is any conflict between the terms in this privacy policy and the EU-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/.
The Federal Trade Commission and the U.S. Department of Transportation each have jurisdiction over Adtelligent’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
Adtelligent provides a software as a service solution to businesses and agencies all over the world that need to manage their (or their clients’) digital advertising resources.
This Privacy Statement applies only to your use of our site and Services. It does not extend to any websites that are linked to from our site (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy statements of any such websites before providing any data to them.
This Privacy Statement applies to:
- Our Site visitors;
- Our Customers (including their internal users);
- End-Users of our Customers who interact with our Customers on their cookie profiles on advertising platforms,
(jointly referred to as “users”, “you”, “your” etc.)
Adtelligent recognizes your right to confidentiality and is committed to protecting your privacy. This Privacy Statement discloses what information we gather, how we use it, and how to correct or change it. You can expect to be hereby notified of:
- What personally identifiable information of yours is collected;
- Who is collecting the information;
- How the information is used;
- With whom the information may be shared;
- What choices you have regarding the collection, use and distribution of the information;
- What kinds of security procedures are in place to protect the loss, misuse or alteration of information under our control;
- How you can correct any inaccuracies in the information.
If any additional questions arise you should direct them to our data protection team reachable at legal@adtelligent.com.
Representation in the EEA
We value your privacy and your rights as a data subject located in the EEA and have therefore appointed Prighter Group with its local partners as our privacy representative for purposes of Article 27 of GDPR and your point of contact.
Prigther Group is a representative company that helps with compliance with privacy laws and is on the side of the consumer to protect their rights under the GDPR. Prighter Group gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data).
All the necessary information about Prighter Group you can reach out by clicking the link below or on its official website https://prighter.com/
If you want to contact us via our representative, Prighter Group, or make use of your data subject rights, please visit the following website: https://prighter.com/q/12482014860
2. Your Personal Information
All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and California Consumer Privacy Act of 2018 (CCPA). For more details on security see section 4, below.
We use your data to provide the best possible services to you. This includes:
- Providing and managing your Account;
- Providing and managing your access to our site;
- Personalizing and tailoring your experience on our site;
- Supplying, personalizing and tailoring our services for your benefit;
- Responding to communications from you (to contact you about your account and provide customer support, including responding to your comments and questions);
- Keeping you informed about the service, features, surveys, newsletters, offers and events we think you may find useful or which you have requested from us AND/OR that you have subscribed to (you may unsubscribe or opt-out at any time by changing your email preferences link in our emails;
- Selling and marketing our services;
- Diagnosing your needs and problems, analyze trends, improve the features and usability of the services, and better understanding our customers and users;
- Analyzing your use of our site to improve your user experience;
- Identification when you login to your account.
We do not collect personal information when you visit our site unless you sign-up for a service, register an account with us, place an order, register, complete a survey, fill in the contact form or subscribe for newsletter.
In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the services we can provide you without your consent for Us to be able to use such data.
When you sign-up for a service, we will ask you for the following personal information: name, surname, your company, billing address and details, skype contact and e-mail address. We may use your personal information to contact you for account purposes.
When you register an account or place an order (upgrade to a paid version of software), we will ask you for the following personal information: name, surname, e-mail, billing address, mailing address, job title, your company, phone number, skype contact and banking details. This information is requested to verify your identity. This information is transmitted via a secure encrypted server using Transport Layer Security (TLS) encryption, more commonly known as HTTPS, the approved industry standard (see Security section below). We may use your personal information to contact you for account purposes.
When you submit feedback or questions via e-mail, or contact us for information about our Web site, we will request your name, your company, messenger contact and e-mail address. We use this information solely to respond to your inquiries.
When you subscribing for a newsletter, we will request your name and email address. We use this information to provide you with the news and information according to your subscription. You can revoke your consent to receive a newsletter any time and your subscription will be cancelled.
We also may collect certain data by automatic means, this may include your IP address; your web browser type and version; your operating system; a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
All performance statistics and data are kept private and any personally identifiable data is not released to any of our partners without your permission. Occasionally, we may reference our own statistics, but the data will be an aggregate of our whole client base, and not identify any one party.
We use your data to provide the best possible services to you. This includes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalizing and tailoring your experience on Our Site;
- Supplying our Services to you;
- Personalizing and tailoring our Services for you;
- Responding to communications from you (to contact you about your account and provide customer support, including responding to your comments and questions);
- To keep you informed about the Service, features, surveys, newsletters, offers, contests and events we think you may find useful or which you have requested from us AND/OR that you have subscribed to (you may unsubscribe or opt-out at any time by changing your email preferences link in our emails;
- To sell or market the Service;
- To better understand your needs, diagnose problems, analyze trends, improve the features and usability of the Services, and better understand and market to our customers and users;
- Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
- To identify you when you login to your account on the Service;
- To enable us to operate the Service and provide it to you.
Also, Adtelligent Services and Platforms processes the data we collect for advertising purposes, including:
- Personalizing ads;
- Placing ads;
- Measuring the effectiveness of ads and ad campaigns;
- Enabling standard advertising controls;
- Analyzing and reporting on ad campaigns and campaign forecasting;
- Preventing malicious or fraudulent activity;
- Improving our Services and Platforms;
- Adtelligent Services provision and business relationships.
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
All personal information relating to our members and clients, including email addresses and personal information, is kept secure and confidential. We do not share, sell, rent or barter any identifiable personal information to any third party without your permission.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following grounds apply:
- You have given consent to the processing of your personal data for one or more specific purposes;
- Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation to which we are subject; and/or
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
We provide a more detailed description below of types of pseudonymous data processing by Adtelligent such as:
- Location. In accordance with your device permissions, we may also receive information about the precise location of your device but only if our clients pass it to us. Precise location may be deemed as sensitive personal information in some jurisdictions;
- Age range, gender;
- User-agent or such device information (Demographic information); frequency of identifiers visiting and viewing with respect to advertising (Behavioral data);
- Adtelligent Personnel data such as contact details (name, email, telephone) and professional details (role).
Pseudonymous user data received from our partners such as:
- Location data. In accordance with your device permissions, we may also receive information about the precise location of your device but only if our clients pass it to us. Precise location may be deemed as sensitive personal information in some jurisdictions;
- Age, range, gender;
- Identifiers: cookie and mobile Ad identifiers (such as IDFA, ADID, GPID etc.,); IP address, data that could be used for fingerprinting, latitude and longitude;
- Demographic information: location, age range, gender, other Publisher-specified demographics (tied to an identifier);
User-agent or such device information; - Behavioral data: frequency of identifiers visiting and viewing Publisher Sites and viewing and taking actions with respect to advertising.
- Publisher Personnel such as contact details (name, email, telephone) and professional and business details (role and billing address).
Our Services and Platforms collect data in the following way:
- From Publishers passing us information so that we can help them monetize ad inventory space on their properties;
- Using cookies and/or pixels;
- From our clients and customers uploading data onto our Platform;
- From clients and partners using our technology to gather data;
Through the displaying ads process;
Adtelligent discloses depersonalized data that is collected to:
- SSP side partners to allow publishers to offer advertising inventory in their Publishers Properties to SSP side partners to bid on and fill that inventory with relevant ads. Regulated by Data Processing Addendum;
- Advertisers or agencies, their clients to help them improve the effectiveness of their – and their client’s – ads campaign. Regulated by Data Processing Addendum;
- Service providers. Regulated by Data Processing Addendum.
- Where we think we’re required to by law. Adtelligent may disclose user information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services, or other necessary third parties for legal, protection, security, and safety purposes, including: to comply with laws or regulatory requirements and to respond to lawful requests and legal process; to protect the rights and property of Adtelligent, our affiliates, agents, customers, and others, including enforcing our agreements, policies, and terms of use and protecting our network and physical assets.
Additionally, we inform you that Adtelligent do not collect sensitive data. In case something will change in this matter and for the purpose to provide the better Services will require more information as well as sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), Adtelligent insures you that we will obtain affirmative express consent (opt in) from you if such information is to be (i) disclosed to a third party or (ii) used for a purpose other than those for which it was originally collected or subsequently authorized by you through the exercise of opt-in choice. In addition, Adtelligent treats as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.
3. Data Collection and Storage
All the data collection on our site and through our products is carried out in a manner clear and transparent to our data subjects. Adtelligent does not affix any spybot or data collection software to any of its products.
We only keep your data for as long as needed to in order to use it for the purposes set in Section 2, and/or for as long as we have your permission to keep it. In any event, we are conducting an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need. Adtelligent primarily stores data about customers and site visitors in the United States. To facilitate our global operations, the we may transfer and access such information from around the world, including from other countries in which we are operating. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”). If you are not accepting this, please refer to our Data Protection Team with correspondent request. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, and legally binding contractual terms between us and any third parties we engage.
4. Security
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our site ad services.
Steps We take to secure and protect your data include:
- Access to the information stored within our servers is restricted to a limited number of our employees;
- We use industry best practices to keep any information collected and/or transmitted to the services secure. The site and our service are all secured by SSL protocol, which provides encryption to all data transmitted;
- We use Transport Layer Security (TLS) encryption, more commonly known as HTTPS, for all of the data that we send and receive. This ensures that all user data in transit is both safe and secure, and additionally only available to the intended recipients. This ensures that online transactions and the transmission of personal information such as credit card details are safe from third-party interception;
- Our servers are protected by a) firewalls establishing a barrier between our trusted, secure internal network and the Internet and b) IP restrictions, limiting access to allowed IPs;
- We use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology to run the Services. These vendors all offer best-in-class security;
- We also use third party vendors to prevent attacks on the site or the services and destruction or theft of any data. Such vendors also monitor potential attacks to inform our customers in the event their content and/or any related data has been compromised;
- We review our information collection and processing practices periodically and will review and amend this Privacy Statement accordingly.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.
5. Data Sharing
We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will accomplish this only under your consent and take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of our site including data on traffic, usage patterns, sales and other information. All such data will be anonymized and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law. In certain circumstances Adtelligent may be legally required to share certain data, which may include your personal information, for example, where there is involvement in legal proceedings, where Adtelligent is complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made by the competent authorities.
6. Transfer of Control
We may, from time to time, expand or reduce our services and this may involve the sale and/or the transfer of control
We may, from time to time, expand or reduce our services and this may involve the sale and/or the transfer of control of all or part of Adtelligent. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use the data for the purposes for which it was originally collected by Adtelligent.
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
We are informing you about Adtelligent’s liability in cases of onward transfers to third parties to transfer personal information to a third party acting as a controller, Adtelligent complies with the Notice and Choice Principles of the Data Privacy Framework. More information about the Notice and Choice Principles is reachable via https://www.dataprivacyframework.gov/framework-article/1%E2%80%93NOTICE. We also enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify the organization if it makes a determination that it can no longer meet this obligation. The contract provide that when such a determination is made the third party controller ceases processing or takes other reasonable and appropriate steps to remediate.
To transfer personal data to a third party acting as an agent, Adtelligent: (i) transfers such data only for limited and specified purposes; (ii) ascertains that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) takes reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) requires the agent to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), takes reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provides a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request.
If you are resident in the EEA, UK or Switzerland, we will protect your personal information when it is transferred outside of your jurisdiction by (i) processing it in compliance with the EU-US Data-Privacy Framework; (ii) processing it in a territory that provides an adequate level of protection for personal information based on the receiving country’s data protection laws; and/or (ii) to the extent that the EU-US DPF, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF is unavailable, implementing appropriate safeguards to protect your personal information, such as requiring the recipient to comply with the Standard Contractual Clauses, or another lawful and approved transfer mechanism.
7. Cookies
To better serve you, we use “cookies” to reduce the time required to login as well as for the continuous improvement of your user experience across our site.
We collect and process a variety of non-personally identifying information in order to prevent fraud and support and maintain a higher quality browsing experience for all users.
To know more about the way we process cookies and use such data, please refer to our Cookies Policy
8. Your Choice/Opt-Out
Adtelligent provides you with the opportunity to remove your personal information from our database and opt out of receiving communications from us at any time. As well you’ve got an opportunity to update or change any information you previously provided. Please contact our data protection team with corresponding request at legal@adtelligent.com or by post at:
Adtelligent Inc., 16192 Costal Hwy, City of Lewes, County of Sussex, 19958 DE
As stated in the paragraph above Adtelligent offers you the opportunity to choose (opt out) whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.
By derogation to the previous paragraph, we inform you that it is not necessary to provide choice when disclosure is made to a third party that is acting as an agent to perform task(s) on behalf of and under the instructions of our company. However, you must be sure that Adtelligent shall always enter into a contract with the agent to regulate and protect your personal data.
Please, see our Cookie Policy for more information on how we use cookies and other similar technologies to get more about opt-out via this way. For more information about cookies in general, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. For more information about how to clear your browser cache, please see your browser’s instructions for doing so. Please note that deleting or resetting cookies and clearing your browser cache will not opt you out of receiving interest-based advertising (including retargeting) from our Services.
9. Right to Withhold Information Withdraw Information After You Have Given it
You may restrict your internet browser’s use of Cookies. For more information, see Cookie Policy.
You may withdraw your consent for Us to use your personal data at any time by contacting Us using the details set out in section 8, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible Services to you.
10. Your Rights Under GDPR
We believe that you should have control over how your information is used and shared. Therefore, we offer you choices and means to manage and limit the use and disclosure of your personal data.
We are providing you access to personal information about you that our company holds to be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the DPF Principles and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S, in your personal Account according to our General Terms of Services, but there are exclusions when where the burden or expense of providing access may be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.
Under the GDPR, you have to following rights as a data subject:
- the right to request access to, deletion of or correction of, your personal data held by Adtelligent;
- the right to complain to a supervisory authority;
- the right to be informed of what data processing is taking place;
- the right to restrict processing of your personal data by Adtelligent;
- the right to data portability;
- the right to object to processing of your personal data by Adtelligent;
- the right to refuse automated decision-making and profiling.
To enforce any of the foregoing rights please contact our data protection team at legal@adtelligent.com
You can exercise these rights by submitting a request through our Data Subject Request as it set out in the beginning hereof, or contacting our Data Protection Officer, or to enforce any of the foregoing rights please simply contact our data protection team at legal@adtelligent.com or by clicking Do Not Sell My Personal Information on our website. Our team or our representation in the EEA shall kindly proceed with your request and provide a reasonable response with the appropriate options to do so in a possible short period. In case any of your personal data is used by Adtelligent for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision by Adtelligent.
The right described in section however does not apply in the following circumstances:
- The decision is necessary for the entry into, or performance of a contract between the you and Adtelligent;
- The decision is authorized by law; or
- You have given your explicit consent for such automated decision-making.
We currently use NO automated decision-making for any purpose.
We currently profile personal data for the purposes of marketing and advertising. Where we use personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
11. Dispute Resolution
Adtelligent will investigate complaints and disputes regarding use and disclosure of Personal Data in accordance with the Data Privacy Principles.
In compliance with the Data Privacy Framework Principles, Adtelligent commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the European Union pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Adtelligent by email at legal@adtelligent.com. For complaints that cannot be resolved between Adtelligent and the complainant, Adtelligent has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the DPF Principles.
Furthermore, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Adtelligent commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to Judicial Arbitration and Mediation Services, Inc. (“JAMS”), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/arbitration for more information or to file a complaint. The services of Jams are provided at no cost to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.
12. Changes to this Privacy Statement
We may change this Privacy Statement as we may deem necessary from time to time, or as may be required by law. Any changes in force will posted on our site in a timely manner and you will be deemed to have familiarized with this Privacy Statement during your first use of our site following the alterations published. We recommend that you check this page regularly to keep up-to-date.