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Privacy POLICY


This website is operated by Adohm, Inc. (hereinafter “Adohm” ). These terms and conditions (“Terms”) govern the privacy practices of the Adohm website www.adohm.com (the “Platform”) and the and services we provide through the Platform (collectively, the “Services” ).


The term “you” or “your” shall refer to any entity or person that starts uses our Services through the Platform and/or opens an Account with us. The terms “we,” “our” or “us” shall refer to Adohm. The term “End User” shall mean any individual who views or listens to, is able to view or listen to, or interacts with, any advertisements placed by you in the Platform, which are delivered through the Services.


Since we may gather certain types of information about our users, we feel you should fully understand our policy and the terms and conditions surrounding the capture and use of that information. This Privacy Policy discloses what information we gather and how we use it. The private information you provide on the Services will be used only for its intended purpose.


BY USING THE SERVICES, YOU CONSENT TO THE DATA PRACTICES DESCRIBED IN THIS STATEMENT. IF YOU DO NOT AGREE WITH OUT PRIVACY PRACTICES, DO NOT USE THE SERVICES.

INFORMATION WE COLLECT

We will collect information, including Personal Information and Non-Identifiable Information, when you interact with us and the Services, for example when you:


  • Access or use the Services
  • Create an account with us
  • Open or respond to our e-mails
  • Contact customer service
  • Visit any page online that displays our ads or content
  • Purchase services on or through our Website

PERSONAL INFORMATION

Personal Information means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. As a general rule, we do not collect personal information about you when you visit and/or use the Services, unless you choose to provide such information to us. Submitting personal information through the Services is voluntary. By doing so, you are giving us your permission to use the information for the stated purpose.

THE NATURE OF PERSONAL INFORMATION WE COLLECT

Personal information we collect which you provide to us may include:

  • Contact Information: your name, email addresses, telephone numbers and postal addresses.
  • Interaction Information: information you provide when you interact with us and the Services, email and other communications; and how you interact with our advertisers and business partners; and
  • Financial Information: information collected from you as needed to process payments for products or services that you buy, as provided by you, if applicable, such as your payment card number, expiration date, and card verification number.

As a general rule, you have the right not to provide the foregoing information when dealing with the Services.

NON-IDENTIFIABLE INFORMATION

We collect and temporarily store certain information about your usage of the Services. NonIdentifiable Information means information that alone cannot identify you, including data such as cookies, pixel tags, web beacons and device information. The information includes, without limitation:

  • Device Data- We may collect information such as: the type of computer and/or mobile device you use; the unique device ID of your computer and/or mobile device; the IP address of your computer and/or mobile device; the operating system of your computer and/or mobile device; and the type of mobile internet browsers of your computer and/or mobile device.
  • Usage details- when you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Services.
  • Location information- When you first visit or use the Services we may request permission to collect and use your device’s precise geolocation. You can opt not to permit the collection of this information, but it may limit certain functions or features of the Services. You can control how and whether we collect your precise geolocation information through your device’s settings.

If you do not want us to collect this information, you may either change your device’s privacy settings or do not access or use the Services.

INFORMATION COLLECTION TECHNOLOGIES

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies): We may use "cookies" on our Services to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. The purpose of a cookie is to tell the web server that you have returned to a specific page. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Services.
  • Web Beacons: Pages of the Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Services statistics (For example, recording the popularity of certain content and verifying system and server integrity.

CHANGING YOUR DATA COLLECTION SETTINGS

We strive to provide you with choices regarding the personal information you provide to us. You may need to adjust the settings on your computer and/or device to restrict the collection of information by the Services, but this may prevent you from accessing all of the features of the Services.

  • Tracking Technologies: You may be able to set your browser or device to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.
  • Location Information: You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Services may then be inaccessible or not function properly. For example, you have the ability to only allow manual geolocation (rather than using their device’s auto locating functionality), but the provision of at least one piece of location data (i.e. you search location) is a requirement for the Services to function.

THIRD-PARTY AUTOMATIC INFORMATION COLLECTION

When you use the Services or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks and ad servers
  • Analytics companies
  • Your mobile device manufacturer
  • Your mobile service provider
  • Your Internet provider

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information about your online activities over time and across different Services, mobile applications and other online sites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE YOUR INFORMATION

We use information collected as described in this Privacy Statement for the following:

Operation

  • Operate, maintain and improve the Services
  • Provide you with interest-based ads, push notifications, communications, and offers for products and services from us based on your precise geolocation
  • Manage your account, including processing payments and refunds
  • Facilitate and fulfill orders placed on the Services;
  • Send you reminders, technical notices, updates, security alerts, support and administrative messages and marketing messages
  • Answer your questions and respond to your requests
  • Ensure that content from our Services is presented in the most effective manner for you and for your computer or device for accessing the Services
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Terms and Conditions; and
  • Notify you when there are changes to any products or services we offer or provide though the Services

Usage and Analytics

  • Estimate our audience size and usage patterns
  • Perform analytics and conduct customer research
  • Evaluate your eligibility for certain types of offers, products or services that may be of interest to you
  • Analyze advertising effectiveness; and
  • Communicate and provide additional information that may be of interest to you about us and our business partners

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

The Personal Information you provide to us whether voluntarily or automatically, may be used and disclosed without limitations, in the following instances:

  • With vendors who provide services for us (who are required to protect the Personal Information)
  • To Report or collect on debts owed to us or our Business Partners
  • With Business Partners from which we offer products and services or whom we have entered into an agreement that provides for the disclosure, sale, lease, or license of your Information
  • To a prospective buyer or buyer of Adohm, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all our assets
  • As part of bankruptcy, liquidation or similar proceeding
  • To comply with legal requirements for the enforcement of law, regulations, court orders, subpoena, a warrant during the course of a legal proceedings or otherwise; or
  • To protect and safeguard our copyright, trademarks, legal rights, intellectual property rights or safety; or
  • In response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States

HOW WE DISCLOSE YOUR NON-PERSONAL INFORMATION

We may also disclose Non-Identifiable Information:

  • For the same reasons we might share Personal Information
  • With our advertisers for their own analysis and research
  • To facilitate targeted content and ads; or
  • With Third-Party Ad Servers to place our ads on the Services and on third-party websites

COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

Each Party represents and warrants that it will comply with all applicable laws, rules, regulations, directives and guidelines regarding the collection, use and disclosure of data collected from or about end users or specific devices which apply to the services utilized hereunder (collectively, the “Rules”). The term “Rules” shall include, without limitation, (i) all United States Federal Trade Commission rules and guidelines regarding the collection, use and disclosure of data from or about end users and/or specific devices; (ii) all United States federal and state laws regarding data collection and data privacy; (iii) the Self-Regulatory Principles and guidance of the Digital Advertising Alliance (“DAA”), the Network Advertising Initiative ( “NAI” ) Code of Conduct and guidance, and, as each set of principles and guidance may be amended or supplemented, or as replaced or superseded, from time to time by the DAA, NAI, or their respective successor entity; and (iv) if applicable, the Rules of any other jurisdiction, including European Union General Data Protection Regulation (“EU GDPR”), rules, regulations and/or directives promulgated by a pertinent Data Protection Act, and all amendments and updates to them or regulations as replaced or superseded from time to time.

HOW TO ACCESS, UPDATE & DELETE YOUR INFORMATION

You have the right to review, correct, update, amend your Personal Information where it is inaccurate, or to request the deletion or destruction of both your Account and Personal Information (“right to be forgotten”). Additionally, you may request a copy of the information we have collected about you by contacting us with your full name, phone number and email address. Please send all requests to info@adohm.com

If you do not wish to have your Personal Information used or shared as described in this policy, please discontinue the use of the Services or do not provide such information. While we strive to honor all reasonable requests, please be aware that we backup the data to prevent accidental or malicious destruction of your information. Information on backup servers may take some time to be completely deleted from the system. If you request that we remove you from our system and delete your Account, please note that you may still receive materials while your request is being processed.

If you request that your Account be deleted, we will keep your Account information for a period of time in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their Account and opening a new Account. However, if you delete your Account, your Personal Information will not be used by Adohm or our third- party providers for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

End Users “Right to be Forgotten” Requests

We shall, to the extent legally permitted, promptly notify you if we receive a request from a Data Subject (as defined in the GDPR) to exercise the Data Subject’s right of access, right to rectification, restriction of processing, erasure, data portability, object to the processing, or its right not to be subject to an automated individual decision making (“Data Subject Request” ). Taking into account the nature of the processing, we shall assist you by appropriate technical and organizational measures, to the extent possible to fulfill your obligation to respond to a Data Subject Request under data protection laws, directives, and regulations. To the extent you, while using our Services, do not have the ability to address a Data Subject Request, we shall upon request provide commercially reasonable efforts to assist you in responding to such Data Subject Request, to the extent Adohm is legally permitted to do so and the response to such Data Subject Request is required under data protection laws, directives and regulations. To the extent legally permitted, you shall be responsible for any costs arising from our provision of such assistance.

Transfer of End User Information.

You shall be responsible for providing appropriate information and obtaining any required consent from End Users, including notice and consent allowing it to own, control, transfer and use as contemplated hereunder, all Personal Information of End Users and including all consents required by social networks for the collection, processing, tracking and tagging of End Users by Adohm on behalf of you as required for the provision of Services hereunder. You shall collect, use, transfer and otherwise process any Personal Information collected by or through the Services in compliance with all applicable laws, enactments, regulations, orders, standards and other similar instruments, including but not limited to the data protection laws and employment laws.

Implementation of your Privacy Policy with End Users

You shall ensure that each of your websites and/or mobile applications that are using our Services contains a privacy policy that:

  • discloses the usage of third-party technology and the data collection and usage resulting from the use of our Services
  • contains a conspicuous live hyperlink to an opt-out website that provides the End User the ability to opt out of interest-based advertising and related collection of information through the Adohm Services; and
  • complies with all applicable privacy laws, rules and regulation

To the extent required by applicable law, rule or regulation, you shall provide us, with respect to the provision of our Services, a copy of your privacy policy with the End Users consistent with the foregoing requirements. You agree that, with respect to all Data, it shall be your responsibility to devise, safeguard, transfer, share and use the Data in compliance with applicable laws, directives, and regulations, including without limitation, any privacy and data protection laws and regulation in connection with the communication of commercial advertisements. You represent and warrant that you accept full and sole responsibility for developing and implementing a satisfactory full data backup and a disaster recovery capability facilitating complete data recovery including restoration or reconstruction of all its lost or altered files data or programs, and the security of all its confidential information, Data and all Personal Information.

SECURITY

We take reasonable steps to protect the personal data provided to us from unauthorized access, use or disclosure. The safety and security of your information also depends on you. Unfortunately, the transmission of information via the internet and mobile services is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of Client’s personal information transmitted through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. If you suspect that there has been a breach of the security of your data you should contact us and include details of the nature of the breach, the date of the breach, and the full circumstances of the breach.

NOTICE CONCERNING CHILDREN UNDER THIRTEEN

We do not direct our website or services directly or indirectly towards children. We do not target the Services towards children, nor do we knowingly collect information about children. We are committed to respecting the privacy of children online and ensuring that we are compliant with the Children’s Online Privacy Protection Act (COPPA). If we learn that the information of a child under the age of 13 is stored within its system, we will promptly delete any information in that Account. If you become aware that a child under the age of 13 has provided us with Personal Information, please notify us immediately at info@adohm.com and we will terminate the Account.

UPDATES TO THIS POLICY

We reserve the right to change, modify, update, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. When we do update it, for your convenience, we will make the updated policy available on this page. We encourage you to check this Privacy Policy frequently to stay up to date on any changes. You can determine if changes have been made by checking the effective date on the Privacy Policy. Continued use of the Services after the effective date of any change in this Privacy Policy will constitute acceptance of such changes and it will signify that you agree to abide by and be bound by the modified Privacy Policy.

OPT-OUT & UNSUBSCRIBE

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from the Services by contacting us at: info@adohm.com

CONTACT US

If you have questions, comments, or concerns regarding this Privacy Policy, please contact us at the following email address info@adohm.com We will respond to your request within a reasonable timeframe, usually within five business days.