Privacy Policy
PURPOSE
This Privacy Policy is provided to help you understandhow Aduclick International FZCO processes (i) end user data on behalf of ourclients, and (ii) your data when you visit ADUCLICK’s corporate family ofwebsites, including Aduclick.com (the “Websites”). It does not state the usepractices or policies of our clients, of the websites or apps on which ads areshown, or of other parties.
'You' shall mean You, the User of the Website/Application/ Service and ‘Yourself’ interpreted accordingly. 'ADUCLICK’ / 'We'/ 'Us' means Aduclick International FZCO and 'Our' interpreted accordingly.'Users' means the Users of the Website/ application/ Service collectivelyand/or individually as the context allows.
ELIGIBILITY
At ADUCLICK, we are committed to respect the privacychoices of our clients and website visitors. We cares about how end user datais collected, used, and shared. We are a “data processor” that collects andanalyses end user data at the specific request of our clients, the “datacontrollers”.
By accessing the Website or using our Services, youbecome subject to this Policy. Your acceptance of the terms of this Policy, intheir entirety, shall be effective to your employees, if any.
THE INFORMATION WE COLLECT
Platform and Data Pledge
Our clients use ADUCLICK services to measure andmanage their online relationships. Clients use ADUCLICK to assess theeffectiveness of their partner relationships and act on those results.
Pursuant to our Data Pledge, our clients determine thedata that they provide to and collect through ADUCLICK. Clients’ use,collection, exportation, or any other use of end user data is governed by theirown privacy policies and applicable laws, rules, or regulations.
What Information Does WE Collect from Clients?
At the direction of our clients, who act as datacontrollers, we collect the following types of information from end users tohelp clients measure and manage their marketing partner relationships:
• AdIdentifiers (unique character strings associated with user devices that helpmonitor and measure user interactions with advertisements and apps, such asApple’s IDFA and Google Ad ID; Ad Identifiers may be reset by the user)
• Cookies
• Pixeltags
• IPaddress Imprecise geographic location data derived from IP address and/or Wi-Finetworks
Our clients may also choose to share certain accountinformation for both clients and their partners on the Platform. This mayinclude corporate and employee information necessary to maintain the servicesand up-to-date contact information, including: name, mailing and/or billingaddress, email address, company name, website URL, user name, password, andphone number. Clients using our service to manage payouts to their partners mayalso choose to share certain banking information as necessary to carry out theservices.
Clients can also choose to view and measureinformation provided by other third-party sources in the Platform. Thosesources may include advertisers, publishers, marketing partners, and otheradvertising networks and analytics partners. Marketing partners may sign upwith advertisers through the ADUCLICK Platform or through their own customerwebsite. Marketing partner information provided to our advertiser clients maybe used by us for fraud prevention purposes and to fulfill contractualrequirements with our advertisers.
Clients own the data that they provide to and collectthrough the ADUCLICK Platform. When clients remove or export their data from theADUCLICK Platform, their use of data is governed by their own privacy policiesand applicable laws, rules, or regulations. ADUCLICK serves as a dataprocessor, acting at the direction of our data controller clients. Specificfields that likely contain personal data, such as IP address or device ID, maybe obfuscated or blanked, respectively, by the ADUCLICK client.
What Information do we collect on the Websites from End Users?
When you visit the Websites, ADUCLICK collectsinformation about your device and use of the Websites to understand how toimprove its Websites. ADUCLICK also collects any information you voluntarilyprovide when you visit the Websites to learn more about ADUCLICK and itsproducts, sign up for our services, or apply for employment at ADUCLICK. Thetype of information collected will depend on your request and interaction withthe Websites.
Categories of information may include specific timesof day you accessed the Websites, the IP address of the device you used toaccess the Websites, the pages on the Websites that you viewed, the pages youvisited before navigating to the Website(s), and information about the deviceyou use to access the Websites, including hardware model, operating system andversion, and browser.
We use the information collected on the Websites forvarious purposes, including:
• Ensuringwebsites remain relevant to end user needs and are easy to use by providinganalytics and other data regarding use of our Websites.
• Sendingmarketing and promotional communications in compliance with applicable laws.
• Enhancing,improving, or modifying its Websites and services, enhancing security, orcombating spam or malware or other security risks.
• Providingconfirmations, invoices, technical notices, updates, security alerts, and othersupport and administrative messages.
HOW WE MAY USE THE USER INFORMATION
How Do Clients Use ADUCLICKTo Collect Information from Users?
Clients may use ADUCLICK for pixel or server postbacktracking to collect certain marketing information about end users. Pixeltracking (also called “cookie-based tracking” or “client-side tracking”)methods store an ADUCLICK session identifier in a user’s browser cookie onclick. In postback tracking (also called “server-side tracking”), ADUCLICKdirectly sends a session identifier to the advertiser on click. On conversion,the advertiser then communicates that identifier to ADUCLICK for validation.
We also support server-to-server measurement for someclients. With any of the mentioned methods, when an end user clicks on anadvertisement and goes to a specific web page or mobile app action that aclient chooses to measure, we collect information from the user’s device,including but not limited to IP address and ad identifiers.
How May Clients Use ADUCLICK To Process Information from End Users?
• Measuringperformance of ad campaigns, including creation of customized performancereports
• Measuringperformance of various marketing partners selected by the client
• Servingads through our services using data that does not personally identify users
• Managingrelationships with marketing partners, including payouts on measuredconversions and establishing automated workflows to establishing advertisingoffers.
Publications
If you no longer wish to receive our publications(e.g. newsletters, blog digests), you may opt out using the unsubscribe linklocated at the bottom of each communication. If you opt out, we may still sendyou non-promotional communications, such as those about your account or ourongoing business relations. We will respond to your opt out request to accesswithin a reasonable timeframe.
END USER CHOICE, OPT OUTS, AND DISABLING COOKIES AND ADVERTISINGIDENTIFIERS
Cookies and WebBecons
You should be aware that information and data may beautomatically collected through the Use of Cookies or web beacons or similartracking technologies. "Cookies" are text files placed in yourcomputer browser that store basic information that a Website can use to recogniserepeat site visits and as an example, recall Your name if this has beenpreviously supplied. We may use this to understand Your service and internetusage, observe behaviour and compile aggregate data in order to improve orcustomize our products, services offerings or the Website, target theadvertising and assess general effectiveness of such advertising. Cookies donot attach to Your system and damage Your files. If You do not want informationcollected through the Use of Cookies, there is a simple procedure in mostbrowsers that allows You to deny or accept the Cookie feature. Note, however,that "personalised" services may be affected if the cookie option isdisabled.
For example, We may use Cookies to personalize Yourexperience at our Services (e.g., to recognize You by name when You return toOur Website), save your password in password-protected areas. We also may useCookies or other tracking technologies to help Us offer You products, offeringsor services that may be of interest to You when You visit this Website. We or athird party platform with whom We work may place or recognize a unique cookieon your browser to enable You to receive customized offers, services on thisWebsite. These Cookies contain no information intended to identify You personally.The Cookies may be associated with de-identified demographic or other datalinked to or derived from data You voluntarily have submitted to Us (e.g., youremail address) that we may share with a service provider solely in hashed,non-human readable form.
We and our Partners may also use "webbeacons" or clear GIFs, or similar technologies, which are small pieces ofcode placed on Our Website or in an email, to monitor the behaviour and collectdata about the visitors viewing Our Website or email. For example, web beaconsmay be used to count the users who visit a web page or to deliver a cookie tothe browser of a visitor viewing that Website. Web beacons may also be used toprovide information on the effectiveness of our email campaigns (e.g., open rates,clicks, forwards, etc.).
End users can disable cookies in most internetbrowsers. An overview of the process is available here. Disabling cookieswill not, however, stop receipt of all advertisements. If an end user wouldlike to opt out of a particular ad network, publisher, or advertiser’s ads,they will need to contact those companies directly to inquire whether they havean opt-out option. End users can also disable collection of Ad Identifiers fortargeted advertising by enabling the Limit Ad Tracking setting on theirsmartphone. End users can also reset the Ad Identifier altogether using theirsmartphone’s privacy settings. ADUCLICK collect data on behalf of its businessclients, and is not an end user facing company.
Local Shared Objects (Flash Cookies) and Local Storage (HTML5) Opt Out
Third parties with whom we partner may use localshared objects (flash cookies), and we and our third parties use local storage(HTML5) to provide certain features on our Websites, to display advertisingbased on your web browsing activity, and to store content information andpreferences. Various browsers may offer their own management tools for removingHTML 5. To manage Flash cookies, please click here.
SECURITY AND DATA STORING
How Does We Adhere to GDPR Principles?
ADUCLICK serves as a data processor under GDPR, andadheres to the principles and rules of GDPR. Specifically, we implementsprivacy by design and default principles, ensures limited data retentionprotocols, adheres to incident response norms, allows for appropriate thirdparty audits, ensures data is only transferred internationally with a lawfulbasis, only contracts with sub-processors with adequate written commitments todata processing, respects data subject rights, does not process sensitivepersonal data, and provides data processing agreements to all appropriateclients and partners. (In addition to GDPR, we respect and adhere to similardata privacy laws in other jurisdictions as well)
To end users who access the Websites: we retain yourinformation for as long as your account is active or as needed to provide youour services. In most cases, reliance on ADUCLICK’s existing data retentionrules will satisfy the end user request within a reasonable period of time. Wewill retain and use your information as necessary to comply with our legalobligations, resolve disputes, and enforce our agreements, unless a longerretention period is required or permitted by law.
Data Retention,Use, Access, Corrections, and Removal
ADUCLICK retains your information for as long as youraccount is active or as needed to provide you ADUCLICK services. ADUCLICKapplies data retention rules to abide by data minimization principles. In mostcases, reliance on ADUCLICK’s existing data retention rules will satisfy theend user request within a reasonable period of time. We will retain and useyour information as necessary to comply with our legal obligations, resolvedisputes, and enforce our agreements, unless a longer retention period isrequired or permitted by law and helpful for the service to function properly.
Under GDPR, you have the right as a data controllerto:
• Requestinformation about the processing of your data, as well as the receipt of a copyof your personal data. You can request information on the purposes of theprocessing, the categories of personal data being processed, the recipients ofthe data (if they are passed on), the duration of the storage or the criteriafor determining the duration.
• Correctyour data. Should your personal data be incomplete, you have the right tocomplete the data, taking into account the processing purposes.
• Deleteor block your data. Reasons for the existence of a cancellation/blocking rightcan be, among others, the revocation of the consent on which the processing isbased, the data subject objects to the processing, the personal data wereprocessed unlawfully.
• Restrictthe processing.
• Objectto the processing of your data.
• Revokeyour consent to the processing of your data in the future.
• Complainto the competent supervisory authority about inadmissible data processing.
Legal Basis
Your data will be processed on the following legalbases:
• Yourconsent to data controllers in accordance with Art. 6 (1)(a) GDPR;
• Forthe performance of a contract with you in accordance with Art. 6 (1)(b) GDPR;
• Forthe fulfilment of statutory obligations in accordance with Art. 6 (1)(c) GDPR;or
• Froma legitimate interest in accordance with Art. 6 (1)(f) GDPR (and, to the extentwe base the processing of your personal data on legitimate interests, such datawill only be sued to improve or carry our services, protect against misuse orfraud, and maintain statistical integrity with business partners andcustomers).
Data Transfers
In the process of providing services to you, we maytransfer information that we collect to affiliated entities, or to other thirdparties across borders from your country or jurisdiction to other countries orjurisdictions around the world. By using the Websites or signing up for anaccount with us, you consent to the transfer of your information to therespective/related country.
Security
ADUCLICK uses commercially reasonable efforts,including a variety of security technologies and procedures, to help protectclient and end user data from unauthorized access, use, or disclosure, bothduring transmission and once it is received.
INFORMATION SHARING AND DISCLOSURES
Except as described in this Privacy Policy, we willnot share personally identifiable information collected on the Websites or inour Platform with other people or non-affiliated companies unless we have yourconsent, or under the following circumstances:
• Withthird party service providers who work for us and need access to yourinformation to do their work on our behalf, such as providing customer supportfeatures, processing payments, and storing data (e.g. Amazon Web Services). Allsuch third-party vendors have agreed to protect the confidentiality ofinformation provided by us.
• Toprotect the rights and property of ADUCLICK, our agents, customers, users, andothers, including to enforce our agreements, policies, and terms of use.
• Ifrequired to do so by law, such as to comply with a subpoena or court order, orin the good-faith belief that such action is reasonably necessary to protectour rights, protect your safety or the safety of others, prevent fraudulent,malicious, or unlawful activity, investigate fraud, or respond to a governmentrequest.
• Aspart of any merger, acquisition, debt financing, or sale of company assets orother event in which information could be transferred to third parties as oneof the business assets of the company.
We may also share aggregated or anonymized informationin a form that does not directly identify you or any end users with any thirdparties.
Our Website includes links to other websites whoseprivacy practices may differ from those of ADUCLICK. If you submit personalinformation to any of those sites, your information is governed by theirprivacy policies. We encourage you to carefully read the privacy policy of anywebsite you visit.
LINKED SERVICES
Our Website may contain links to or integrations withother services such as Facebook, Twitter, LinkedIn, and other media servicesand platforms whose information practices may be different than ours. Visitorsshould consult these other services' privacy notices as we have no control overinformation that is submitted to, or collected by, these third parties.
GOVERNING LAW AND JURISDICTION
This Privacy Policy is governed by and operated inaccordance with the laws of India. If any of the parties wish to seek legal recourse,they may do so by using the courts of law in New Delhi.
ACCEPTANCE
By visiting our website, signing up or logging intothe website, uploading information on our website; you acknowledge andunconditionally accept the policy. If you do not agree with this Policy, do notuse our website and services or provide here any of your personal data.
UPDATES
Aduclick may find it necessary to update this PrivacyPolicy from time to time. Please check this Privacy Policy regularly, as anychanges will be posted on this site.
If you have an unresolved privacy or data use concernthat we have not addressed satisfactorily, or have any questions regarding thisPrivacy Policy, or would like more information on our privacy practices, pleasecontact us at sales@adu.click