In addition to personal information that we may receive from you, AdAction, our service providers, and our advertising partners may automatically collect other information about Users over time on our Platform and other sites and online services, such as:
We may use the following technologies to facilitate some of this automatic data collection:
AdAction participates in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about you so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on the Platform, or on other web sites.
In addition to the information that we collect from you directly or automatically, we may also receive information about you from other sources, including other Users and Customers, our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, and other third parties or publicly available sources.
To Provide the Platform and Services . We use personal information to provide the Platform and operate our business. For example, we use personal information to:
Research and Development . We use personal information for research and development purposes, including to study and improve the features and functionality of our Platform and our business, understand and analyze the usage trends and preferences of our Users, and develop new products and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
Direct Marketing . We may send you AdAction-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “YOUR CHOICES” section below.
To Comply with Laws and Regulations . We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety . We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Platform and our products and services, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Platform; and € prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With Your Consent . We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
Related Companies . We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with AdAction).
Service Providers . AdAction may share your personal information with service providers that perform services for AdAction that are necessary for the orderly operation of our business. For example, we work with service providers that perform hosting services, provide marketing assistance, analyze User data, process payment card information, fraud protection, database management, and for other legitimate purposes.
Social Media Platforms . The Platform may offer you the ability to share your personal information through a social networking site (e.g., Facebook, Twitter, LinkedIn), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. Additionally, by making personal information available on the Platform, AdAction may provide such personal information to a social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
Advertising Partners . We may also share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Platform for the purposes described in the “Behavioral-Based Advertising” section above.
Professional Advisors . We may share personal information with persons, companies, or professional firms providing AdAction with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
Law Enforcement . Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Compliance . We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”
Business Transaction Participants . We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
4. PUBLIC FORUM AND MESSAGING . We may provide functionality that enables you to disclose personal information to other Users of the Platform and the public. For example, AdAction may offer public discussion forums and bulletin boards. Please note that information that you disclose in these public forums becomes public. Use caution in disclosing any personal information. The Platform may also allow you to exchange messages with other Users. We may store these messages in order to deliver them and allow you to manage them. You may also be able to submit content to the Platform (such as advertising material, comments, questions, stories, reviews, blogs, photos, and videos), and we will identify you by displaying information such as your company name, username, social media handle, or a link to your user profile (as applicable) along with the content you submit. We do not control how other Users or third parties use any personal information that you make available to other Users or the public.
6. YOUR CHOICES. You may make the following choices regarding your personal information:
“Do Not Track” Signals . Some web browsers may be configured to broadcast a “Do Not Track” signal to the online services you visit. At this time, the Platform does not currently respond to “Do Not Track” signals. To find outmore about “Do Not Track,” please visit http://www.allaboutdnt.com.
Cookies . Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Websites may not work properly. For more information about cookies, including how to see what cookies havebeen set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Analytics . The Websites may use Google Analytics to help us analyze how the Website is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the GoogleAnalytics Opt-out Browser Add-on, available here.
Advertising Choices . You can limit the use of your information for behavioral-based advertising by using the methods set forth below. Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described below, so even after opting-out, you may still receive behavioral-based advertisements from other companies. If you opt-out of behavioral-based advertisements, you will still see advertisements online but they may be less relevant to you.
7. RETENTION OF PERSONAL INFORMATION . AdAction retains your personal information:
Your Rights . In accordance with applicable data protection laws, you may have the right to request: access to, rectification, and erasure of your personal information; restriction of processing of personal information; objecting to certain processing of personal information; and the right to data portability. Where any processing of personal information is solely dependent upon your consent, you have the right to withdraw such consent at any time (for example, by using the unsubscribe link contained in an applicable marketing message, or, emailing us at the “Communications” details below). If we do not have access to such personal information from you, then we will not be able to undertake certain Services for you. We may withhold information where the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested. To exercise your rights under these provisions, please contact us at the “Communications” details below. When we receive your requests, we may ask you to verify your identity before we can act on your request. Where you believe that we have not processed your personal information in accordance with applicable data protection laws, you may lodge a complaint with the respective supervisory authority or data protection regulator. In theEuropean Economic Area, you can find your data protection regulator here. Inthe United Kingdom, you can find your data protection regulator here.
|Processing Purpose (as described above in the “Use of Personal Information” section)||Legal Basis|
Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or via the relevant Services.
Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.
|To Comply with Laws and Regulations||Processing is necessary to comply with our legal obligations.|
|For Compliance, Fraud Prevention, and Safety||Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.|
|With Your Consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or via the relevant Services.|
Cross-Border Data Transfer . If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us as at the “Communications” details below for further information about any such transfers or the specific safeguards applied.
11. INTERNATIONAL OPERATIONS . AdAction is based, and this Platform is hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to AdAction, please note that any personal information that you provide to AdAction may be transferred to the United States of America. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.
Users located in Europe can view more information about cross-border transfers in the section titled “Notice to European Users.”
AdAction Interactive LLC
Attn: AdAction Legal Department
If AdAction needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.
Effective as of April 07, 2023