PRIVACY POLICY

Important information about AdsWizz:

AdsWizz and its affiliates (collectively referred to as “AdsWizz“, “we”, “us”) take our data protection and privacy responsibilities seriously. This privacy notice explains how we collect, use and share your personal information in the course of our business activities, including:

  • What personal information we collect and when and why we use it;
  • How we share personal information within AdsWizz and with our service providers, regulators and other third parties;
  • How we transfer personal information globally;
  • How we protect and store personal information;
  • Legal rights available to help manage your privacy; and
  • How you can contact us for more support.

The AdsWizz entity responsible for your personal information will be the AdsWizz entity that originally collected the information from or about you. Unless we tell you otherwise, the entity that will be responsible for your personal information is AdsWizz Inc. The Contact Us section below provides additional information on AdsWizz Inc.

We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice.

You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third-party site.

I. WHAT PERSONAL INFORMATION DO WE COLLECT; WHEN DO WE COLLECT PERSONAL INFORMATION; AND FOR WHAT PURPOSES DO WE USE PERSONAL INFORMATION WHEN ACTING AS A DATA CONTROLLER.

In this section you can find out more about

  • the types of personal information we collect;
  • the cases in which we collect personal information;
  • the purposes for which we use personal information; and
  • the legal basis for using personal information.

We collect your personal information if you do any of the following:

      • use one of our website(s) or online services;
      • purchase or receive one of our services;
      • are identified as a potential customer;
      • work with us as a business partner; and/or
      • apply for a job at AdsWizz.

collectively (“you”).

A. When you use our websites or online services

Our website collects your personal information (such as your name, address, telephone number, or email address) when you voluntarily submit such personal information through a form on our website (e.g., when you submit a request for information about our services).  Additional information that may constitute personal information (e.g., browser type, operating system, IP address, domain name, number of times you visited the website, dates you visited the website, and the amount of time you spent viewing the website) may be collected via cookies and other tracking technologies. Aggregated information (such as how many times visitors log onto our website) may also be collected. To find out more about our use of cookies check out our Cookie Policy.

We may use the collected personal information in the following ways if we believe that we have an appropriate legal basis to do so:

How we use your information:
Legal basis for our use of your information:
To make improvements to our websites and our user experience based on your use of our websites.
Our use of your personal information is based on our legitimate interest to improve our websites and user experience.
To respond to inquiries you submit through the website.
Our use of your personal information is based on our legitimate interest to respond to your submitted inquiries.
To provide you with marketing materials for our products and services and to identify our products and services that you may be interested in.
Our use of your personal information is based on either: (i) your consent if you have registered to receive our marketing communications; or (ii) our legitimate interest as a commercial organisation to market our products and services.

B. When you purchase one of our products or services:

Where you purchase or receive our services, we may collect:

  • basic identification and contact information (such as your name, address, telephone number, gender, national ID number and/or email address) in order to fulfil your order, provide our services and/or manage your account;
  • demographic information (e.g., age and information about your occupation);
  • financial information (such as bank account information, tax registration information, billing and details) in order to manage and process your payments to us;
  • information held by credit references agencies and fraud prevention agencies, in order to assess your creditworthiness and other qualifications to use our services; and/or
  • information about your use of our products and services and your satisfaction with our products and services, for product and service improvement purposes.

You may be required to provide us with certain personal information in order to purchase one of our products or services (e.g., your name, contact information and payment details).  If you do not provide us with such information, we may not be able to provide you with our products and services.

We will use the personal information provided to us when you purchase our products or services in the following ways if we believe that we have an appropriate legal basis to do so:

How we use your information:
Legal basis for our use of your information:
Set-up and ongoing management of your account.
When you enter into a contract to receive our products and/or
services in your personal capacity, our use of your personal information is necessary to perform our
contract with you. In addition, our use of your personal information in this case is based on our legitimate
interest as a commercial organisation providing services to you.
If an entity that employs you or has engaged you on its behalf has entered into a contract to receive our
services, we will process your personal information on the basis that it is necessary to use your personal
information based on our legitimate interest as a commercial organisation to provide our services to your
employer/ entity that engaged you.
For credit management and payment processing for your account.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to implement appropriate credit management processes.
For credit verification purposes and to assess your qualification
to receive our services.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to implement appropriate credit verification and processing protocols.
To provide general customer service and to respond to your
questions and complaints relating to our products and services.
When you enter into a contract to receive our services in a
personal capacity our use of your personal information is necessary to perform our contract with you. In
addition, we use your personal information based on our legitimate interest as a commercial organisation to
provide our services to you.
If an entity that employs you or has engaged you on its behalf has entered into a contract to receive our
services, we will process your personal information based on our legitimate interest as a commercial
organisation to provide our services to your employer/ entity that engaged you.
To deliver requested services.
When you enter into a contract to receive our services in a
personal capacity, our use of your personal information is necessary to perform our contract with you. In
addition, we use your personal information based on our legitimate interest as a commercial organisation to
provide our services to you.
If an entity that employs you or has engaged you on its behalf has entered into a contract to receive our
services, we will process your personal information based on our legitimate interest as a commercial
organisation to provide our services to your employer/ entity that engaged you.
To: (i) evaluate your use of our products and services in order to
assist with our development of new products and services; and (ii) make improvements to our existing
products and services.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to develop and improve our products and services.
For fraud prevention purposes and to monitor our customers’ use of
our services for fraud detection.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to put in place measures to detect and prevent fraud.
To monitor, maintain and improve: (i) our IT environment; and (ii)
the applications used by AdsWizz and our customers to manage our services.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to operate our IT systems and to provide our products and services.
To maintain your access to our network and applications.
When you enter into a contract to receive our services in a
personal capacity, our use of your personal information is necessary to perform our contract with you. In
addition, we use your personal information based on our legitimate interest as a commercial organisation to
provide our services to you.
If an entity that employs you or has engaged you on its behalf has entered into a contract to receive our
services, we will process your personal information based on our legitimate interest as a commercial
organisation to provide our services to your employer/ entity that engaged you.
To provide you with marketing materials for our products and
services and to identify our products and services that you may be interested in.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to promote our goods and services.
To conduct focus groups, perform customer relationship management
activities and implement customer satisfaction surveys in order to improve our products and services.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to manage customer relationships and improve our products and
services.
For employee training purposes.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to provide appropriate employee training.
In order to enable us to comply with legal and/or regulatory
requirements.
Our use of your personal information is necessary to comply with
applicable legal and/or regulatory requirements.

C. When you are identified as a potential customer

We collect information directly from you, from AdsWizz affiliates, and from other third party lead generation providers, about companies that may be interested in receiving information about our products and services. In connection with providing potential customers product information, we may collect basic identification and contact information (e.g., name, address, telephone number, and email address) in order to provide you with marketing materials for our products and services.

Specifically, we may collect:

  • basic identification and contact information (such as your name, address, telephone number, gender, and email address); and/or
  • demographic information such as your age and information about your occupation.

We will use information collected in connection with marketing potential customers in the following ways if we are satisfied that we have an appropriate legal basis to do so:

How we use your information:
Legal basis for our use of your information:
To provide you with marketing materials for our products and services and to identify our products and services that you may be interested in.
Our use of your personal information is based on our legitimate interest as a commercial organisation to promote our goods and services.
To conduct focus groups and implement customer satisfaction surveys in order to improve our products and services.
Our use of your personal information is based on our legitimate interest as a commercial organisation to improve our products and services.
In order to enable us to comply with legal and/or regulatory requirements.
Our use of your personal information is necessary to comply with applicable legal and/or regulatory requirements.

D. In connection with commercial relationships where you provide goods and/or services to AdsWizz:

Where you, or your employer, are engaged by us to provide goods or services to AdsWizz, we may collect any of the following:

  • basic identification and contact information (such as your name, address, telephone number, and email address) in connection with our contract to receive your services;
  • demographic information such as your age and information about your occupation;
  • financial information (such as bank account information, tax registration information, billing and details) in order to manage and process payments we make to you; and/or
  • information provided by credit and fraud prevention agencies for risk management purposes.

We will use personal information provided in connection with commercial relationships in connection with services provided to us in the following ways if we believe that we have an appropriate legal basis to do so:

How we use your information:
Legal basis for our use of your information:
For budgeting, accounting and financial reporting purposes. In
addition, to process payments to your employer.
Our use of your personal information is based on our legitimate
interest as a commercial organisation implement budgeting and financial reporting processes.
To make payments to you.
When you enter into a contract to provide services to us in a
personal capacity, it is necessary to use your personal information in connection with the contract.
For credit management and payment reporting.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to implement appropriate credit management processes.
To monitor, maintain and improve: (i) our IT environment; and (ii)
the applications used by AdsWizz and our customers to manage our services.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to operate our IT systems and to provide our services.
To provide you with marketing materials for our products and
services and to identify our products and services that you may be interested in.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to promote our goods and services.
To conduct focus groups, perform customer relationship management
activities and implement customer satisfaction surveys in order to improve our products and services.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to improve our products and services.
For employee training purposes.
Our use of your personal information is based on our legitimate
interest as a commercial organisation to provide appropriate employee training.
In order to enable us to comply with legal and/or regulatory
requirements.
Our use of your personal information is necessary to comply with
applicable legal and/or regulatory requirements.

E. When you apply for a job using our website:

When you apply for a job at AdsWizz, we may collect any of the following:

  • basic identification and contact information (such as your name, address, telephone number, and email address) in order to contact you, schedule job interviews and keep you updated of the status of your job application;
  • demographic information such as your age and information about your current occupation;
  • professional qualifications and information concerning your application and our assessment of your qualifications and application,  your references, background checks (including, if permitted  under applicable law, criminal records checks) and any information connected with your right to work. If relevant and permitted by applicable law, we may also process information concerning your health and/or any requested accomodations.

We will use personal information collected in connection with job applications in the following ways if we believe that we have an appropriate legal basis to do so:

How we use your information:
Legal basis for our use of your information:
To evaluate your application.
Our use of your personal information is based on our legitimate interest to ensure we select the most qualified candidates for job openings.
Any processing of your health data is conducted on the basis that such processing is necessary in order for us to comply with applicable employment laws.
To schedule interviews/meetings.
It is in our legitimate interest to conduct candidate interviews.
To increase the number of potential candidates in our jobs database. Unless you inform us that you do not want us to retain your information, we may keep your contact information, resume and other information submitted as part of the job application process to contact you about future positions.
Our use of your personal information is based on our legitimate interest to create and maintain a database of candidates for job openings.

II. SHARING PERSONAL INFORMATION WITHIN ADSWIZZ, WITH OUR SERVICE PROVIDERS, OUR REGULATORS.

In this section, we provide you with information on how we share personal information:

  • with AdsWizz subsidiaries and affiliates;
  • with third parties that help us provide our products and services; and
  • with regulators.

We share your information in the manner and for the purposes described below:

  1. with entities that are corporate affiliates of AdsWizz, where such disclosure is necessary to provide you with our services and/or to manage our business;
  2. with third parties who help manage our business and/or provide services to us. Such third parties agree to confidentiality restrictions and use any personal information we provide to them, or which they collect on our behalf, solely for purposes of providing us with goods and services. Such third parties include IT service providers who help manage our IT and back office systems and marketing agencies who help us market our products and/or services;
  3. to our professional services providers, such as accountants and law firms;
  4. with regulators to comply with any applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
  5. we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our business partners, affiliates and/or advertisers; and
  6. If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third-party acquirer.

III. TRANSFERRING PERSONAL INFORMATION GLOBALLY

In this section you can find additional information on:

  • how we operate as a global business and transfer data internationally; and
  • the arrangements we have in place to protect your personal information if we transfer your information overseas.

AdsWizz operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU, including the United States of America, that are subject to different standards of data protection.

If you are located in the European Union, or your personal information is processed by an AdsWizz group company that is located in the European Union and that is acting as the controller of your personal information, the following details apply to the transfers of your personal information:

AdsWizz will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we are satisfied that alternative arrangements are in place to protect your privacy rights. To this end:

  • we ensure transfers between AdsWizz and our affiliates will be covered by intercompany agreements which contractually obligate the applicable AdsWizz affiliated entities to ensure that personal information receives an adequate and consistent level of protection whenever it is transferred between AdsWizz and our affiliates;
  • if we transfer your personal information outside AdsWizz or our affiliates or to third parties who help provide our products and services, we obtain contractual commitments from such providers to protect your personal information. Some of these assurances include certification schemes like the EU – US Privacy Shield for the protection of personal information transferred from within the EU to the United States; and
  • if we receive requests for information from law enforcement or regulators, we carefully verify these requests before we disclose any personal information.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information in case of transfer as described above.

IV. HOW WE PROTECT AND STORE YOUR INFORMATION

Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures that are designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information (which measures are appropriate to the nature of the applicable information). Measures we take include: (i) implementing confidentiality requirements for our employees, consultants and service providers; (ii) destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected; and/or (iii) encrypting personal information at rest if systems permit.

Storing your personal information

We will store your personal information for as long as is reasonably necessary for the purposes for which the information is collected, as described in this notice.  In addition, we will store your personal information in order to comply with our legal, regulatory, tax, and accounting requirements.

In the event we receive a complaint or if we reasonably believe there is potential action or litigation relating to your personal information, we will retain your personal pending resolution of the applicable complaint, action or litigation.

V. LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY UNDER EUROPEAN LAW.

If you are located in the European Union, or your personal information is processed by an AdsWizz group company that is located in the European Union and that is acting as the controller of your personal information, you have certain rights in relation to your personal information.  These rights are subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking. Click on the links below to learn more about each right you may have:

  • To access personal information
  • To rectify / erase personal information
  • To restrict the processing of your personal information
  • To transfer your personal information
  • To object to the processing of personal information
  • To object to how we use your personal information for direct marketing purposes
  • To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
  • To lodge a complaint with your local supervisory authority

Before disclosing the personal information requested, we may ask you for additional information in order to confirm your identity and/or for security purposes. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other applicable considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: (a) the source of your personal information; (b) the purposes of processing; (c) the categories of personal data; (d) where possible, the period during which your personal data will be stored, or the criteria used to determine such period; (e) details on your data subject rights including the right to file a complaint with a supervisory authority; (f) the existence of automated decision making and related details; and/or (g) the entities or categories of entities with whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. However, we may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in the following limited circumstances:

  • the information is no longer needed for the purposes for which it was collected;
  • you have withdrawn your consent (if the data processing was based on consent and there is no other legal ground for the processing);
  • following a successful right to object (see right to object);
  • it has been processed unlawfully; and/or
  • to comply with a legal obligation to which AdsWizz is subject.

We are not required to comply with your request to erase personal information in certain circumstances, including if the processing of your personal information is necessary:

  • for compliance with a legal obligation; and/or
  • for the establishment, exercise or defence of a legal claim.

Right to restrict the processing of your personal information

You can ask us to restrict your personal information if:

  • in case of questions as to the authenticity of the information, to allow us to verify its accuracy;
  • the processing is unlawful, but you do not want the information erased;
  • the information is no longer needed for the purposes for which it was collected, but you need us to retain the information in order to establish, exercise or defend legal claims; and/or
  • you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction in certain circumstances, including:

  • if we have your consent;
  • to establish, exercise or defend legal claims; and/or
  • to protect the rights of another natural person or entity.

Right to transfer your personal information

You can request that we provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case, only if:

  • the processing is based on your consent or on the performance of a contract with you; and
  • the processing is carried out by automated means.

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal information for direct marketing purposes

You can request that we change the manner in which we contact you for marketing purposes; you also have the right to object to our processing of your personal information for direct marketing purposes.  If you object to our processing of your personal information for direct marketing purposes, we will no longer process your personal information for this purpose.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can request a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

However, we may redact sensitive commercial terms from the information provided to you.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.

We ask that you please attempt to resolve any issues with us first; however, you have a right to contact your supervisory authority at any time.

VI. PROCESSING DATA THAT WE RECEIVE FORM THIRD PARTY CONTROLLERS

In this section you can find out more about:

  • the types of personal information we receive form third party controllers;
  • how we use personal information we receive from third party controllers; and
  • transfer to third parties

As a technology provider, we offer online radio and video publishers and advertisers the ability to get to know their audience by providing precise session-based measurements.  In this context, we may receive personal data from publishers and advertisers.  In connection with the personal data that we receive from publishers and advertisers (i.e., the data controllers), we are acting as a data processor.  This means that we only process such personal information in accordance with the instructions of the publishers and advertisers who are responsible for the processing by AdsWizz of your personal information.  You may find additional information on the processing of your personal information by AdsWizz on behalf of publishers and advertisers who are data controllers.  However, please note that you should consult the data protection notices of the relevant publishers and advertisers for full details on the processing of your personal information.

  1. Information we may receive from data controllers

    Based on the instructions of data controllers, we may collect and process your personal data, including location data, online identifiers (such as IP addresses) and, if available, cookies or advertising IDs.  We do not collect, receive or process your name, physical address, email address, or phone number.  We may share your personal data with the following data sub-processors if instructed to do so by the data controller: (i) demand-side platforms; (ii) data management platforms; (iii) ad networks; and/or (iv) analytics platforms.

  2. How we use personal information we receive from data controllers

    We use the personal data received from or collected on behalf of data controllers to:

    • deliver digital audio to listeners and to enable the publishers of digital audio content to improve the listening experience and delivery of digital audio advertisements; and/or
    • provide advertising delivery, measurement, and streaming and podcasting delivery reports.
  3. Who do we share personal information received from controllers with?

    We may share your personal information with data sub-processors or independent data controllers if we are instructed to do so by the publishers (i.e., data controller). We may share personal data with the following partners based on the data controller’s instructions: (i) demand-side platforms; (ii) data management platforms; (iii) ad networks; and/or (iv) analytics platforms.

VII. CONTACT US

AdsWizz Inc. is a Delaware corporation that is headquartered at 487A South El Camino Real, San Mateo, CA 94402, United States. 

AdsWizz Inc. has appointed AdsWizz Romania, with registered address at 246C Calea Floreasca, SkyTower – 18th & 35th floor,  S1 – Bucharest,  014476 Romania, as its representative in the European Union for the purposes of the General Data Protection Regulation.

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us using the contact details below. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timeframes provided by applicable data protection laws. 

We may be reached at: privacy@adswizz.com

You may also contact our Data Protection Officer by emailing the following:  dpo@adswizz.com.

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