Effective date: March 10, 2019

This privacy policy is aimed to inform both users (‘Customers’) of Spotad Ltd. (“we”,“us” or “our”)  from our website www.spotad.co (‘Our website’) as well as end users (‘End users’) of our advertisements on how we collect and use certain information.

Spotad Ltd. allows advertisers to buy digital advertisements on ad exchanges, publishers, applications and web sites. An account is required to access the Spotad Platform and manage digital campaigns. Because of the creation of such accounts, Spotad Ltd. acquires personally identifiable information (PII) on the Costumer. By interacting with our advertisements through third party websites and/or applications, End users also provide us (through publishers and ad exchanges) with information considered in some regions as PII (e.g. IP Address).

We believe that Spotad Ltd. services enhance our users’ web experience. If you do not want us to collect any further information from you via our ad serving technology, you may follow the opt-out process mentioned herein.

ABOUT THIS POLICY

This Privacy Policy governs our use and disclosure of information that we collect when you visit a website that directly or indirectly uses the Spotad services, or view advertisements we serve. This Privacy Policy does not otherwise apply to the practices of other websites, such as those of our publishers and advertiser clients, or other services or companies that we do not own, manage or control. We do not control the privacy practices of such third parties, and you are subject to the privacy policies of those third parties when you use their services.

Spotad Site

INFORMATION COLLECTED BY SPOTAD’S WEBSITE

 

As we explain in more detail below, we may collect information about you in the following ways: when you complete a registration form; when you use, or interact with Spotad services; when you visit a website that directly or indirectly uses the Spotad services; or when you view or respond to advertisements served by us or on our behalf.

Direct Information

We collect “Direct Information,” which means any information that you directly give us. For example, by registering with us, you will be directly giving us certain information, some of which identifies you personally, such as your name, email address, and other registration information. From time to time, you may also directly give us additional information about yourself if you engage in any other transactions with us, such as when you give us your phone number to seek customer support.

Usage Information

We collect “Usage Information,” such as general clickstream behavior, web pages viewed (including the URL addresses and content of such pages), search queries from which you are directed to a page, navigation from page to page through our publisher networks, time spent on each page, items that you click or select, IP address, cookie-based information, information about your geographic location (e.g., derived from your IP address), and your Internet Service Provider.

Technical Information

We also collect “Technical information,” such as the type of browser you are using (e.g., Google Chrome or Mozilla Firefox), the type of operating system you are using (e.g., Windows or Mac OS), the central processing unit on your computer, and your manner of connecting to the Internet (e.g., connection speed through narrowband or broadband access).

Information from Third Parties

Together with the information that we collect from you, we may combine non personally identifiable information (e.g., demographic information such as zip code) that we receive from our publishers, advertiser clients and other third parties. For example, we may also receive publicly available information from third party websites with whom you have registered (e.g. social networks).

We receive information about consumers from third parties to enable targeted advertising on the website(s) and application(s) that we support. The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Spotad.

 

INFORMATION USED BY SPOTAD LTD.

 

We may use your Direct Information to: (a) fulfill requests for our services; (b) communicate with you and respond to your inquiries; (c) conduct research about the use of the Spotad Ltd. services; (d) enable you to create an account, store login credentials, and customize your access and use of Spotad Ltd. services; (e) contact you from time to time about Spotad Ltd. services; and (f) provide offers for products and services of Spotad Ltd. and our partners, publishers, advertiser clients and other third parties that may be of interest to you.

 

SHARING INFORMATION

 

Direct Information

 

We do not sell Direct Information, nor do we share any Direct Information (including any Direct Information combined with other Usage Information or Technical Information) with any third party for marketing purposes.

We may disclose any information we collect, including your personally identifiable information, if: (a) you specifically authorize it (e.g., you respond to an offer made by a third party on the Spotad services or you use our social media services); or (b) we reasonably believe that we are required to do so by law, regulation or other government authority or to protect our rights and property or the rights and property of the public or any user.

 

Information Shared for Advertising

 

We use non-personally identifiable Direct Information, Usage Information (e.g., Audience Segments) and/or Technical Information with third party advertisers and publishers to assist us and them in delivering relevant, personalized advertising that is aligned with user interests. For example, these companies may use such information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) to provide advertisements about goods and services that are likely to be of greater interest to you. Your preferences collected through this process may be used to influence a selection of types of marketing messages that you receive across websites of our publishers, advertiser clients and other third parties.

Please note that our publishers’ websites and their independent advertisers may independently collect other demographic information about you after they place their own cookies or web beacons on publishers’ websites. The use of cookies and pixel tags by our publishers, advertiser clients and other third parties are subject to their own privacy policies. We are not responsible for the information practices of these third parties.

Spotad platform and Ad services

 

When you interact with a sites/applications that offers ad spaces via supply exchanges  for the purpose of displaying advertisements within the site/app , we receive and collect a variety of information about your device and the ads that you view. The Publisher site/app is responsible for obtaining your consent, if required and as applicable, to enable us to collect information from your device. This consent is passed via consent mechanism (see IAB Transparency and Consent framework), in which Spotad is a member of.

INFORMATION COLLECTED BY SPOTAD PLATFORM

Information about your device

We may collect some or all of the following information about your device: device identifiers, which may include Google Advertising ID (GAID), ID for Advertisers (IDFA); device type (e.g., mobile, tablet); type and version of operating system (e.g., Android, iOS); network provider; IP address; mobile browser (e.g. Safari, Chrome, etc.); timestamp; manufacturer and device model; language setting; time zone; network status type (such as WiFi);Location details (e.g. Country, Region, City, Lat, Lon)

Information about ads you view

We collect some or all of the following information about the ads we serve you: (i) what the ad is about; (ii) the ad type (e.g., text, image, or video); (iii) where the ad is displayed within the Site/App; and (iv) certain information regarding what you do when interacting with or after viewing the ad (e.g., whether you proceed to purchase the product advertised).

 

INFORMATION USED BY SPOTAD PLATFORM

 

We may use the Information that we collect to assemble non-personal, demographic and behavioral information to group users that share a common interest into “Audience Segments.” These Audience Segments do not contain personally identifiable information; for example, these segments may disclose that a user located in a geographic area may be interested in cars, but these segments do not identify or include the name, e-mail address, phone number, mailing address, or user name of any specific individual. We may use these Audience Segments to: (a) match advertisements that may be of interest to our users that fall within that segment; and (b) assist our publishers, advertiser clients and other third parties to deliver advertisements and offers that may be of interest to users within a given segment.

 

We use such information for other related purposes (e.g., research to better understand the results of our online advertising campaigns or the interests or activities of users of the Spotad Ltd. services). We may also be engaged by any publisher that uses the Spotad platform & services to collect Usage Information on such publisher’s websites, obtaining additional information about such publisher’s own users and in accordance with such publisher’s privacy policy (rather than for our independent purposes).

We may use Information to analyze  browsing patterns & content usage, in order to optimize ad targeting.

 

AUTHORITY

By accessing or using the Spotad Ltd. services, you represent and warrant that you are at least eighteen (18) years of age, and that you have the right, authority and capacity to enter legally binding agreements under applicable law.

ACQUISITIONS

We reserve the right to transfer your information (e.g., personally identifiable information) in the event of a transfer of ownership of Spotad Ltd. and/or its relevant assets, such as acquisition by or merger with a different company. If the different company plans to materially change this Privacy Policy, you will be notified beforehand.

SECURITY

We implement physical, electronic and procedural restrictions to protect confidentiality of your personally identifiable information.

 

Spotad has verified that all of the third-party service providers we work with for cloud computing are also GDPR compliant with mutually signed data processing addendums. This is done in order to ensure that we protect and secure  all the data that is collected, as stated in article 5 (among others) of the GDPR.

 

Retention of data collected on the platform

As described above, we process your personal data for different purposes, and the length of time that we retain your personal data varies depending on the processing purpose, the category of personal data and certain external factors.

We will retain all categories of personal data that we collect or receive on the Platform, including Bid Request Data and Impression Data, Pixel Data and Other Client Data, and Third-Party Segment Data and Other Third-Party Data, for no longer than six months, and we retain much of this data for shorter periods of time.

3rd parties used by Spotad

Spotad uses third party solutions and services cloud computing and infrastructure
management & orchestration. Spotad shall remain responsible and liable under the
Privacy Shield Principles if its third party agent processes such personal information on
Spotad’s behalf in a manner inconsistent with the Privacy Shield Principles, unless
Spotad proves that it is not responsible for the event giving rise to the damage.

Your legal rights

Spotad will respect your legal rights to your data as listed below:

• the right to access your personal data,
• the right to rectify or erase your personal data (“right to be forgotten”),
• the right to restrict the processing of your personal data,
• the right to object to the processing of your personal data
• the right to withdraw your consent to processing of your personal data (although the withdrawal of consent does not affect the compliance of the processing that was made on its basis before the withdrawal of consent),
• the right to data portability.

The EU-U.S Privacy Shield Compliance

Spotad complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use, and retention of personal
information transferred from the European Union to the United States.
Spotad has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. 
If there is any conflict between the terms in this privacy policy and the Privacy Shield
Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy
Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Spotad commits to resolve complaints
about our collection or use of your personal information.  EU individuals with inquiries
or complaints regarding our Privacy Shield policy should first contact Spotad at: 
privacy@spotad.co

As a Privacy Shield participant, Spotad commits to binding arbitration at the request of
an individual to address any complaint relating to our privacy notice or our information
practices that has not been resolved by other recourse and enforcement mechanisms
The Federal Trade Commission has jurisdiction to investigate claims against Spotad
regarding possible unfair or deceptive practices and violations of laws or regulations
covering privacy.

EU DATA PROTECTION AUTHORITIES COMPLIANCE

We may transfer your personal data outside the European Economic Area, i.e., to the
territory of the United States of America, for which the European Commission has
adopted an adequacy decision (Privacy Shield), in order to protect the storage and
processing of data using IT services, as well as operate the Site and provide the Services.
The EU-U.S. Privacy Shield framework is a “partial” adequacy decision (concerning only
the companies committing to or abiding by the binding Privacy Shield principles).
Spotad is committed to cooperate with the EU data protection authorities (DPAs) and
comply with the advice given by such authorities with regard to data transferred from the
EU.

END USER OPT-OUT

If you wish to block these identifiers, you will need to change the relevant settings on your mobile device. Some, but not all, mobile platforms allow you to manage settings specifically; on others you can only control cookies at a global level. Details on how to do this vary based on your mobile device operating system and browser, but common cases can be addressed as follows:

• Apple instructions for how to Limit Ad Tracking on devices such as iPhones and iPads
• Google instructions for how to express choice on Android devices

Periodically, you may click the “Incognito” button to “hide” yourself for a limited time, so that we will disable (during such time) our tracking of your additional Usage Information for targeting purposes, but you will continue to receive advertisements tailored to your preferences and usage. This “Incognito” option applies only to Spotad’s tracking feature and does not apply to cookies or web beacons that are used by our publishers, advertiser clients and other third parties.

Most Internet browsers are initially configured to accept cookies. If you prefer, you may configure your Internet browser to refuse cookies, but you may not be able to receive certain benefits of Spotad if you do so

 

CHILDREN’S PRIVACY

Spotad Ltd. follows to the Children’s Online Privacy Protection Act. We do not create nor use any behavioral advertising segments of children under 13 as part of our Services. Our Site is not directed at children under the age of 13. If we are made aware that we have received personally identifiable information from someone under 13, we will use reasonable efforts to remove that information from our records.

PRIVACY POLICY UPDATES

Spotad Ltd. reserves the right to update this privacy policy at any time and publish changes on our website. Users are advised to regularly read up on our current privacy policy.

 

CANCELLING YOUR ACCOUNT

You may cancel your account with us at any time, by submitting a request to support@spotad.co. We will act on your request as promptly as possible.

 

You can manage and control your privacy rights by contacting our Data Protection Officer: privacy@spotad.co