Effective date: May 25, 2018
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
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.
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.
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.
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).
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.
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.
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 may use Information to analyze browsing patterns & content usage, in order to optimize ad targeting.
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.
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.
Transferring data outside the EEA
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).
In such cases your personal data will be transferred to the territory of the USA in accordance with applicable laws and with appropriate safeguards in place only to Privacy Shield certified vendors or by using standard contractual clauses adopted by the European Commission, or based on other applicable transborder data transfer mechanisms.
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.
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.
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.
CANCELLING YOUR ACCOUNT
You may cancel your account with us at any time, by submitting a request to email@example.com. We will act on your request as promptly as possible.
You can manage and control your privacy rights by contacting our Data Protection Officer: firstname.lastname@example.org