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Privacy Policy

Last updated: 1.25.2022

SmartyAds is committed to protecting your privacy.

Please read this document (“Privacy Policy”) carefully and with attention. If you have any questions please consult your attorney.

Section I. General Provisions.

Who we are.

Use of the terms "we" and "us" in this Privacy Policy means SmartyAds Inc., a Delaware corporation having its principal place of business in New York, and its affiliates, including SmartyAds LLP, a limited liability partnership having duly organized under the law of England and Wales. We are a software development company that is focused on providing various services in a digital advertising market. We create and operate various digital technology platforms and render related services that connect buyers with sellers of advertising inventory. Please read about SSP, DSP, and DMP technologies to understand what we are doing better. We are also actively involved in software algorithms and APIs for developers.

This Privacy Policy.

This Privacy Policy explains how information, including personal information, may be collected, used, and disclosed by SmartyAds advertisement materials and/or inventory with respect to the following instances:

(i) use of this website located at www.smartyads.com (the "Website" or the "Site"), and

(ii) how personal information is collected, used, and processed through our technology on behalf of the online advertisers, publishers, business partners, and other businesses that use SmartyAds advertisement materials and/or inventory or services (hereinafter referred to as “clients”).

Our Services and Compliance with Law.

Providing our services, we typically do not directly interact with the owners of personal information unless the owner of information is our client. Rather we process information (including personal information, if any), provided by our clients using various software and services, and not always our software in this regard. Therefore, we obligate our clients to comply with all applicable laws in all applicable jurisdictions, while obtaining information and to indemnify us of any claims arising from such non-compliance. We do not directly target any particular group of personal information owners and intend to act in compliance with the laws of our jurisdiction. We police our client’s compliance with the laws of the jurisdiction where the information we process derives from to the extent it is technically possible and practicable. If you are our client, we collect information in accordance with our agreement and this Policy

If you would like to read the information regarding our services and possible use of personal information, please read Section II of this Privacy Policy. If you would like to know about the information collected solely on this Website, please read Section III of this Privacy Policy. If you are our client, please refer to our agreement and then to this Policy (if applicable).

Information Our Clients and Vendors Collect.

As stated herein, our clients, our contractors, and our clients’ contractors may use our technology and operate it using tags, pixels, cookies, or other similar technologies for their business activities. We are not responsible for our clients, or our clients’ contractors manner of use of your personal information or any sort of tracking technologies.

Contact Us

If you have questions, want to find out more about our privacy practices, or if you would like to make a complaint, please contact our Data Protection Officer by e-mail: dpo@smartyads.com or by post using the details provided below:

SmartyAds, Inc.

Attn: Privacy Officer

31W 34th Street 8035

New York, NY 10001

Changes to this policy.

We reserve the right to revise this Privacy Policy from time to time. The most current version of the Privacy Policy will determine the order and procedure of your information usage and will always be reflected on our Privacy Policy page. This Policy version can be changed or modified by SmartyAds any time without notice, though we will provide notice of any material changes to how we use previously collected personal information. You are responsible for reviewing the terms of this Policy from time to time to ensure you agree with it and any applicable changes. Your continued use of the Website constitutes your acceptance of the new Privacy Policy.

Section II. Information Collected from end users or owners of personal data other than our clients.

Information We Collect, Process, or Store

In the course of providing services to our clients we do not intentionally collect information that reveals your real-world identity, such as your name, address, phone number, or social security number. Our clients may use our services to process some sensitive information, which may come from our clients’ websites and may be processed through our technology without our awareness or control of thereof. Rather we collect data about your computer or device using a number of technologies, the explanation to which you will find below. The information we collect is pseudonymous, generalized, and is not considered to be personal information in the majority of jurisdictions. In some other jurisdictions in which we provide services to our clients, in certain contexts, such information, including Internet Protocol (IP) addresses and other pseudonymous information, like certain unique device identifiers that may identify a particular computer or mobile device (for instance, in European Union)) may be considered to be personal information.

Please take notice, that we may work with third party data platforms or applications that may be directly integrated into our technology or used separately, supplementing our technology by us or our clients. It helps to deliver targeted advertisements using our advertising technology more efficiently or it allows our clients to use multiple interfaces and manage data more efficiently. Finally, our clients may use third-party data in combination with your user information to deliver targeted advertisement materials and/or inventory across multiple devices that may ultimately be processed by our technology without our knowledge thereof.

Information that we may process includes:

YOU SHOULD REVIEW THE PRIVACY POLICY AND TERMS OF USE FOR ANY SITE OR APPLICATION YOU VISIT OR INSTALL TO LEARN ABOUT WHAT INFORMATION THOSE SITES COLLECT FROM YOU, AND HOW THEY USE AND SHARE SUCH INFORMATION. THE INFORMATION IN THIS PRIVACY POLICY MAY NOT REFLECT WHAT AND HOW OUR CLIENTS OR WE COLLECT ON ANY INDIVIDUAL SITE.

  • Information about your behavior on our client’s resources, websites, and platforms: including information about the domain, your referring website addresses, date and time of your visits, page view data, search keywords, visitor activities and actions on publisher’s sites, referring and exit pages, platform type, date/time stamp, geolocation (including city, country, zip code, and potentially geographic coordinates if you have enabled location services on your device), click data, types of advertisements viewed.
  • Information about your browser: your browser type, languages, browser history etc.
  • Information about your device: including information about your IP address, device make, device model, device operating system, device operating system version, and data connection type.
  • Information about your Internet service: including information about which Internet Service Provider (ISP) you use.
  • Information regarding your interactions with our clients, including your use of our clients’ websites, software, and mobile applications, the websites and applications or other pages on the Internet or other resources our clients operate and control.
  • Any additional data that is reasonably necessary to calculate a statistical ID in certain cases.
  • Pseudonymous and generalized information collected by our clients or third parties that may include identifiers (similar to mobile advertising IDs and alike) and interest-based advertising data related to or connected with said identifiers.

How We Collect User Information.

We act on assumption that consumers prefer relevant ads, tailored in accordance with their interests. Therefore, we collect a variety of data using cookies and various other standards (typical for the industry) and unique (if our technology allows so) web technologies to collect information automatically from your device, including:

Cookies.Cookies are a technology that is based on a small-size data files containing a string of alphanumeric characters that usually include a unique identifier and are placed on a visitor’s device or computer. Cookies are usually stored at user’s computer permanently (persistent cookies) or temporally. We use cookies on our clients’ websites in order to operate our technology and collect user information and statistically analyze advertisement preferences.

Tags and Pixels. Tags and Pixels are blocks of code that we and our clients may use to track your browsing on the Internet: from resources to any particular websites or applications to track your browsing behavior. Sometimes web beacons are used for these purposes. They are usually transparent or invisible graphic images, no larger than 1x1 pixel, they are placed on a page or otherwise, Internet resource or sent within an e-mail to monitor the behavior of the user visiting the resource or sending the e-mail. It is often used in combination with cookies. We create and use a unique synchronization system to check the quality of information that we have collected with information that our clients collected independently, and later help our clients or third parties that intend to provide you with targeted advertisements.

Mobile Device Identifiers. Mobile Device Identifiers or Mobile Device IDs are unique identifiers which can be used to identify a mobile device. We may use standard device identifiers, to track your use of mobile applications and to determine if a piece of advertisement inventory has been delivered to a specific user or retargeted, or to determine the frequency of certain inventory for a certain user. Ultimately, passing device’s ID back to advertisers helps us and our clients to improve the quality of advertising and its efficiency.

Software Development Kits. These are blocks of code or algorithm similar to Tags and Pixels that are embedded into a digital resource that allows us to track certain information related to the application use, gathered during the process of utilizing our technology.

Other technologies. Please be aware that we use other technologies, including locally stored objects, to collect user information in order to assist users with the inventory delivery and to provide reporting to our clients or to evaluate the quality of advertisement.

How We Use User Information.

The information that we collect about you, both personally identifiable information and non-personally identifiable information, may be used by us, or shared by us as set forth in this Privacy Policy or otherwise with your consent. If we or our affiliates are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale or company assets, or transition of service to another provider, then any information may be sold or transferred as part of such a transaction as permitted by law and/or relevant agreement.

We primarily use the user information we collect to enable our clients to find and purchase advertising space. In particular, our clients use two types of information in order to deliver end users a targeted advertisement material: our client’s information and information that we provide in the course of our services delivery. Those two types of information are usually synchronized and mutually filtered and checked to identify what are the main interests of the user, and what targeted advertisement materials should be sent to him or her based on all the information that we stated as collected in this section.

Additionally, we may use the information that we collect directly for our purposes: to create sophisticated advertising segments, to run analytics, including forecasting analytics of inventory, and to check the quality of advertisement or for any other and further research and development purposes acceptable as our legitimate business interests. Further, we constantly improve our algorithms targeting users with particular advertisement materials and/or inventory and measure the efficiency of advertisement materials. We use user information to improve our services and products that we provide to our clients, and to develop new products and services, to analyze the market, and generate performance reports. For said purposes we may share information with our clients, partners, and service providers, taken, however, that all the information sharing is done in aggregate without identifying particular users. Finally, we use user information to protect users, investigate security breaches, and to prevent all illegal activities within our systems.

SUBSECTION FOR EEA USERS ONLY

Your Rights and Applicability of the EU Laws

Our Data Protection Officer can be reached via e-mail: dpo@smartyads.com or by post using the details provided below:

SmartyAds, Inc.

Attn: Privacy Officer

31W 34th Street 8035

New York, NY 10001

(we have provided this information in Section I as well)

Legal basis for Processing EEA Users’ Information.

If you are a user located in the European Economic Area (hereinafter the “EEA”), as defined in GDPR, or United Kingdom our legal basis for collecting and using your user information shall be a subject to particular circumstances of collection and/or processing your information. The basis for collection, storage, or processing your personal data is your informed consent or where we have a legitimate interest in processing the personal data. Where we rely on consent to collect and/or process your user information, we obligate our clients to obtain such consent in compliance with applicable GDPR provision and applicable laws.

With respect to personal data collected through our services, we are acting as a processor. With respect to personal data collected through our website, we are acting as a controller.

If you have questions or need further information regarding the manner of use and legal basis for collecting and using your user information, please contact us. Please be advised that we will require reasonable proof that you are a subject to GDPR protection in order to process your inquiry in accordance with this subsection.

Data Subject Rights of The Residents of The European Economic Area

If you are a resident of the EEA, you have certain data protection rights. SmartyAds endeavours to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information, thus to enforce all rights provided to you under the GDPR.

The GDPR gives certain rights to individuals in relation to their personal data. Accordingly, SmartyAds are happy to offer transparency and access controls to help users take advantage of those rights.

You (as a ‘data subject’) may send official requests to us regarding your personal data via email to the following address: dpo@smartyads.com

At any time, you have the following rights:

  • Right to access – This right allows individuals to obtain confirmation as to whether personal data concerning them is being processed and provide access to such personal data It also allows individuals to request details of the processing of their personal data including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
  • Right to rectify – This right allows individuals to rectify any inaccurate personal data about them.
  • Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
  • Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
  • Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
  • Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling, and providing for purposes of scientific or historical research and statistics.

To exercise any of these rights, please contact dpo@smartyads.com.

Right To Lodge a Complaint With A Supervisory Authority

You have the right to lodge a complaint with a supervisory authority.

Legal Necessity.

We process personal data in case of necessity to comply with applicable laws and regulations. For instance, for the mere purpose of identification, the jurisdiction of the information and where it comes from, we have to collect user IP address. Similarly, your mobile device identifier will likely be used (unless our technology allows otherwise), in order to identify a user who had withdrawn his/her personal data processing consent. Similarly, as soon as you withdraw your consent, we will have to provide our clients with your personal information to make sure that your consent has been withdrawn throughout the entire system.

Legitimate Interest.

In some cases, legitimate Interest allows us to process certain information without consent: for instance, to prevent fraudulent activity. Legitimate interest use will be determined by us on ad hoc basis for each particular platform or service.

END OF SUBSECTION FOR EEA USERS ONLY

UK Data Subject Rights

After Brexit, the UK is no longer regulated domestically by the EU's General Data Protection Regulation (GDPR), which governs processing of personal data from individuals inside the EU. Instead, the UK now has its own version known as the UK-GDPR (United Kingdom General Data Protection Regulation). The new UK-GDPR took effect on January 31, 2020.

Under the UK-GDPR, individuals can exercise: the right to be informed; the right of access; the right to rectification; the right to erasure; the right to restrict processing; the right to data portability; the right to object to processing; the rights in relation to automated decision making and profiling

If you would like to exercise any of these rights (as a resident of UK) , please contact us with a reasonable proof that you are subject to these rights.

Please note, as we already stated most information we deal with is anonymized when we receive and process it, therefore, we cannot identify you individually, you need to provide us with some additional information to enable us to identify the user information you are referring to, it may be technologically impossible to identify your information, although we will try to accurately fulfill your request. Please also read regarding our responsibility for the actions of our clients in Section I.

Data Protection Rights of The Residents of Brazil

SmartyAds comply with the principles and requirements of data processing under the Lei Geral de Proteção de Dados Pessoais (LGPD), including, but not limited to, age-gating requirements. All the data received by using our services is anonymized and therefore falls outside the scope of LGPD.

We hereby inform You about the following rights You have under the LGPD:

  • Confirmation: confirmation of the existence of processing;
  • Access: access to the data;
  • Rectification: correction of incomplete, inaccurate or outdated data; anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of LGPD;
  • Data portability: portability of the data to other service providers or suppliers of product, at the express request;
  • Anonymization: anonymization, blocking or elimination of the personal data processed with the consent of the data subjects, except in the events set forth in article 16 of LGPD;
  • Deletion: You have the right to have their personal data deleted if the processing of that data was based on consent;
  • Information: You have the right to be informed about sub-processors and other third parties that access or process their personal data. You also have the right to be informed about Your consent choices and the consequences of refusing consent;
  • Revocation: revocation of the consent, pursuant to the provisions of paragraph 5 of article 8 of LGPD;
  • Bring complaint: lodging a complaint with the Data Protection Authority;
  • Opposing the processing of personal data where there is non-compliance with the provisions of LGPD;
  • Request review: You have the right to request the review of decisions made solely on the basis of automated processing of personal data which affect Your interests. This includes decisions used to define Your personal, professional, consumer and credit profile, or the aspects of Your personality.

If You would like to exercise any of these rights, please contact us via: dpo@smartyads.com

Data Protection Rights of The Residents of China

SmartyAds comply with all the principles and requirements of data processing under the Personal Information Protection Law (the “PIPL”). The beforementioned principles includes among others: accuracy, accountability and security, purpose limitation, collection limitation, openness and transparency, lawfulness and necessity.

We hereby inform You about the rights You have under the PIPL:

  • You have the right to know, decide, refuse, and limit the handling of their personal information by others unless laws or regulations stipulate otherwise;
  • You have the right to access and copy Your personal information in a timely manner, except when the laws and regulations require confidentiality;
  • You have the right to correct or complete inaccurate personal information in a timely manner;
  • You have the right to request Us to explain Our personal information handling rules;
  • You have the right to deletion of Your personal information if (i) the agreed retention period has expired, or the handling purpose has been achieved; (ii) We as a personal information handler cease the provision of Our services; (iii) You rescind consent where the processing of personal information was based on Your consent; (iv) the information is handled in violation of laws, regulations or agreements;
  • You have the right to request Us to transfer Your personal information to another personal information handler.

If You would like to exercise any of these rights, please contact us via: dpo@smartyads.com

Data Protection Rights of The Residents of Virginia and Colorado

SmartyAds expresses its willingness to comply with any and all the principles and requirements of data processing under Colorado’s Consumer Data Protection Act (CPA) that will be effective on July 1, 2023, and under Virginia Consumer Data Protection Act (VCDPA) effective January 1st, 2023.

If You have any questions in regard to Your rights under the aforementioned legislation, please don’t hesitate to contact us via: dpo@smartyads.com

Storage and Sharing of User Information.

We only store information in case of necessity. Typically, we delete all the information quarterly based on the analysis of the traffic and inventory quality control. Some information such as cookies may expire in accordance with your device settings. We do not need such information and we usually delete it unless it is necessary for performing our services to the client.

Please be aware that certain laws and regulations may subject us to store user information for a particular period: money laundering laws, financial reporting regulations, tax laws etc. Furthermore, we may have to comply with the decision of the court of appropriate jurisdiction and maintain information for the longer period.

We share user information that we collect as follows:

We share information with our clients. It is done to help them identify, buy advertising, and target particular publishers. Clients may use this information in conjunction with other information they have independently collected to provide you targeted advertising materials. They also evaluate and analyze particular advertisement campaigns, inventory, etc.

Change of Control. We may share user information in connection with mergers, acquisitions, events of change of control, including but not limited to sale or transfer of all or a part of our business or assets. In this case, your informed consent, if applicable, will be granted to a new entity in accordance with the event of a change of control.

Compliance with laws and regulations. We may share 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 but not limited to the purpose of compliance with laws or regulatory requirements and to responses to lawful requests including requests of governmental entities, enforcement of our own policies and agreements, protection of our clients, agents, employees, directors, officers and alike.

Other service providers. SSP, DSP, and DMP services are based on specific platforms that actively communicate with other platforms, including but not limited to other SSP, DSP, and DMP platforms. Additionally, we use services of various third parties in order to analyze data, prevent fraud, host data, maintain, and support our client’s platforms, and for such other and further related services that are necessary to provide our services.

Your Choices to Avoid Targeted Advertising.

Please be aware that although we believe that targeted advertisement is beneficial for all parties involved, we do not circumvent any devices, and there are many ways and technologies to stop receiving targeted advertising that our clients may apply using our technology. Note that different platforms and devices use different identifiers and different technologies, and also that each browser and each device has its own applicable settings. Please be advised that should you delete your cookies the information of your withdrawal from a targeted advertisement may also be deleted. Same may be applicable to cookie-blocks. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers, except as required by applicable law.

If your consent to the targeted advertisement was granted through the application, please withdraw your consent directly from that application. In addition, your device setting likely allows you to generally withdraw or block personalized advertising: for instance, in iOS, you can do that by changing appropriate “Limit Ad Tracking” setting; on Android devices, you can do so by changing “Opt out of Ads Personalization” setting. Please be advised that this Provision is not intended to serve as your user manual for your device, and you should always contact the manufacturer to obtain all relevant information on how to withdraw your consent.

Security

To prevent unauthorized access and disclosure, to maintain data accuracy, and to ensure the appropriate use of your information, we utilize industry standard physical, technical, and administrative procedures to safeguard any personal information we collect. Please note that no transmission or storage of information, however, can ever be guaranteed to be completely secure, though we take all reasonable precautions to protect against security incidents.

Policy towards children.

Our services are not directed to people under 18. If you become aware that your child has provided us with personal information without your consent, please contact us. We do not collect personal information from children under 18. If you are a minor, you may use our services only in conjunction with a parent or guardian.

Section III. This Website and Information Collected therein.

By using the Site, you are accepting the terms of this Privacy Policy.

IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS THIS WEBSITE OR OTHERWISE USE THE SITE, REGISTER AS A PUBLISHER OR ADVERTISER OR ENTER ANY PROMOTION.

Collecting Personally Identifiable Information.

For purposes of this Privacy Policy, “Personally Identifiable Information” shall mean any information obtained through your use of the Website. This section does not refer to any information we store, collect, or process using our services.

The Personally Identifiable Information that you must submit in order to register as an Advertiser or Publisher, or to enter into an agreement with us, may include, without limitation, your name, title, company name, mailing/billing address, e-mail address, telephone number, Skype name, credit card information and/or bank account information. To the extent Personally Identifiable Information has been collected from you, you acknowledge that such collection is done on a voluntary basis to enable us to provide you efficient access to our materials and/or inventory, services, promotions, and our other products and/or services.

Collecting Non-Personally Identifiable Information.

We automatically collect Non-Personally Identifiable Information when you access and use this Website. This Non-Personally Identifiable Information includes, without limitation, the type of browser that you use (e.g., Internet Explorer, Chrome, Safari), your IP address, the type of operating system that you use (e.g., Windows or Mac OS), and the domain name of your Internet service provider (e.g., Verizon, AT&T).

We use Non-Personally Identifiable Information to help diagnose problems with our server, to personalize your Internet experience, and to identify ways of making the Website better. We also may use this Non-Personally Identifiable Information in the aggregate to analyze Site usage, as well as to offer you products and services. This Non-Personally Identifiable Information is not linked to any Personally Identifiable Information.

IP address.

An IP address is automatically assigned to your computer every time you establish a connection to the Internet. SmartyAds advertisement materials and/or inventory uses your IP address to help diagnose problems with our server and to administer our website. When you open an account on SmartyAds advertisement materials and/or inventory, your IP address will be associated with personally identifiable information.

Cookies

We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while staying on our site. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period. You can remove them by following directions provided in your Internet browser's "help" file.

Cookies Opt-out

You can "Opt-out" from having cookies stored on your PC when advertisement materials and/or inventory are shown from SmartyAds. To "Opt-out" click this link.

Policy towards children

Our Services are not directed to people under 18. If you become aware that your child has provided us with personal information without your consent, please contact us. We do not collect personal information from children under 18.

Important Information Regarding Social Media Websites, Testimonials, and Blog Comments Management.

Please pay attention, due to the fact that our blog is maintained with a help of the third-party service, you might need to register before leaving a comment. Please also note that we are not eligible to manage your personal information or data placed in the comment section of our blog by users. In case you need to delete information containing your personal information from the comments on our blog, you’ll have to login into a third-party application or address them directly with your data deletion request.

Be aware, such tools like social media widgets, buttons, social media scripts, hyperlinks to FB, LinkedIn, Google+ or Instagram, along with Twitter, and Telegram messenger services, belong to the third-party app providers. These third-party app providers may utilize above-mentioned tools for: information collection about your on-site behavior (pages visited), viewing your IP address, and cookies collection in order to optimize and streamline your browsing experience.

All of your actions and the way you interact with these social media tools, features or the social media, gets subjected solely to their privacy policies.

Submitting your data directly through social media, as well as via comments, and forum sections on websites, remember that your personal ID information can be accessed (in case you haven’t restricted your social media privacy settings), and used by the third parties without your consent or pre-agreement.

Hence, we don’t bear any kind of responsibility for your personal information that you submit through the comments. The testimonials from customers belong to the confirmed and approved kind of information, if you would, with your consent, username, and info, we can arrange your own testimonial placement on our site. In case you want to delete, modify, or edit your existing testimonial, don’t hesitate to contact us via privacy@smartyads.com.