Privacy Policy

Adludio Privacy Policy

Background

Adludio Limited, will be referred to herein as “Adludio,” “we,” “us,” and “our.”

• Adludio serves and distributes advertising content online that may include video and non video content.
• Our clients are mostly advertisers that ask us to display their content through banners and other advertising units on web sites, both desktop and mobile devices that participate in our network of publisher sites.
• In this Privacy Policy, we will refer generally to the video and non-video ads and other content we serve as “Distributed Content” and the sites we work with in our publisher network which offer and display our clients’ as “Participant Sites.”
• When you use the Adludio Site or service provided by Adludio, you — as an advertiser or publisher client or other user of our site — are accepting this Privacy Policy, and Adludio will have the right to use your information as described in this Privacy Policy.
• If you do not agree to have your information used in any of the ways described in this Privacy Policy, you must discontinue use of any and all services provided by Adludio.
• By using the Adludio Site, you are consenting to the transfer of your personal data to countries outside the EEA. This is explained in more detail below.
• By using any Adludio site, you are consenting to the placing of cookies and other telecommunications tools on your device which allow Adludio to collect certain information.
• We provide more detail on this below.
• If you have any queries about how we collect or use your personal data, please contact us at info@adludio.com

This Privacy Policy will describe the kinds of information Adludio may collect from or use or disclose about you or your computer or device when you visit an Adludio site or when you encounter Distributed Content served by Adludio at a Participant Site.

All Participant Sites are operated or controlled by third parties, and the collection, use and disclosure of information collected by a Participant Site or other parties working with such site are governed its or their privacy policies. This Privacy Policy does not apply to the Participant Site or such other parties.

Technologies Used by Adludio to Collect Information

Adludio reserves the right to use one or more varieties of technologies to collect information at Participant Sites and Adludio sites. These are listed and described below.

Pixels.
• A tracking “pixel” is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel.
• Adludio collects technical and usage information (see below) through the use of tracking pixels.

Cookies.

• A cookie is a small piece of text sent to your browser by a website you visit.
• It allows it to remember information about you, such as your preferred language and other general settings.
• Most of the cookies are stored in your browser which usually gives you the ability to manage them (though browsers for mobile devices may not offer this possibility).
• Cookies play an important role. Without them, browsing the web would be a much more frustrating experience, as they participate to the simplicity and ergonomics of the online daily routine.
• We mainly use cookies to deliver you the most relevant ads.
• Cookies help achieving the most effective targeting – and that is what keeps thousands of websites free of charge.
• Without them, it is harder for an advertiser to reach its audience, or to collect crucial statistics such as the number of views or clicks on an ad campaign.
• Working with our participant sites, we may use cookies for a number of purposes, such as showing ads that are likely to be more relevant (that can be based on your country, language, or interests for example), as well as preventing you to watch the same ad over and over again.
• It is obviously in the viewer’s interest to be shown an ad campaign concerning a brand or a product he might need or be interested in.
• Adludio uses cookies on the Adludio site to help regulate and facilitate the use by our clients of the console and other client account areas.
• Adludio may also set cookies, on its own behalf or for a client’s or other third party’s benefit (see below sections entitled “Clients” and “Third party suppliers or services”) to store information (on an anonymous basis) about the browsing activities of the one or more users of a connected device or its web browser(s) when displaying Distributed Content.
• A user may configure his or her web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being set.
• In addition to our own cookies, we work with various reputable companies to help us deliver the best possible experience.
• Adludio may use publicly available information or information provided by partners to help customize some of the advertising you see. (see Third party suppliers or services)

Clients.
• Some advertisers or other clients (and their third-party service or technology providers) may use pixels, cookies, flash cookies, web beacons and/or similar technologies which are activated when their Distributed Content is viewed by users across our network of Participant Sites or At the Adludio site.
• We may request and receive aggregate, non-personal information from our clients from time to time but we do not actively seek from our clients (or their service providers) any information about any individual users.

Third party suppliers or services.

• Adludio does from time to time work with third party technology or service providers, such as, for example, Amazon Web Services.
• These may provide it with hosting, serving, general campaign or site analytics, ad serving data, or demographic and other audience data about the use and viewership of our clients’ Distributed Content, the Participant Sites we work with or the Adludio site.
• Such third party providers may utilize pixels, cookies, flash cookies, web beacons and/or similar technologies that may be activated when our clients’ Distributed Content is encountered on a Participant Site or a user arrives at the Adludio site.
• Further, Adludio may work with or permit certain contracted third parties to use our video player to serve cookies, web beacons or similar technologies to collect information about you in order to serve you with targeted ads at other sites you may visit on the Internet or elsewhere, such as to re-target you (or, your browser) with display advertising that is directly relevant to a video advertisement or other advertising unit served by Adludio which you may have viewed.
• In such instances, our video player will provide links to information regarding such third parties, their privacy policies and how to “opt-out” of such third party data collection efforts.
• To be clear, in all instances where the use, collection and disclosure of information is by one of these third party providers, their privacy policies shall govern and this Privacy Policy does not apply.
• We do not actively seek or knowingly receive information from these third party providers about individual users.

Opt-Out.

Adludio adheres to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. To learn more about interest based or online behavioral advertising, and other advertising companies’ privacy practices and opt-out from each or any of them (including Adludio), you may also go directly to the DAA website at http://www.aboutads.info/choices/.

Information collection on participant sites

When you visit a participant site in our advertising network and view distributed content placed by us, we collect information about your activities as follows:
Technical Information:
• When we serve distributed content, we log and analyse technical information that is openly available to our servers such as information about the kind of browser being used (e.g., Safari, Internet Explorer), the type of operating system it’s running on (e.g., Windows, Mac OS, mobile OSes), the speed and type of Internet connection (e.g., narrowband, broadband, mobile), and other technical information.
• This information is anonymous and generally non-personally identifiable but does include “internet protocol addresses” or “IP addresses” which can be used to identify a user and may be considered to be “personally identifiable information” (see below).
• Adludio archives all technical information (including any such IP addresses) in raw log format.

IP Addresses:
• Adludio analyses “internet protocol addresses” or “IP addresses” in order to determine an approximate geographic location so that we can serve a client’s Distributed Content that is more relevant to that location and/or perform other analyses based on information that may be collected about the history of interactions with our advertising units (see below) or clients’ Distributed Content that are common to any single or range of IP addresses.
• We may also collect or use IP address information for fraud detection or prevention.
• We archive IP address data as part of the raw log files of technical information maintained by our systems (see above).
• Unless you use a static IP address, an IP address typically relates to multiple businesses, households or larger communities. For example, if you use an Internet Service Provider (ISP) to access the Internet, your IP address may be assigned from a range of IP addresses.
• Adludio has no influence or control over how any IP address is assigned. An assigned IP address may also change from time to time within that range of IP addresses.
• While not impossible, especially if a user has been assigned an IP address permanently or for a period of time, it is difficult to identify an individual user based on an IP address and we do not actively associate IP addresses with any other information in order to identify any individual user on a personally identifiable basis.

Advertising Campaigns.
• Some Distributed Content may seek to collect personally identifiable or other information as part of a promotion or other offering by our advertising client or the Participant Site.
• If a user provides the requested information, Adludio may collect, store and provide such information to its client. Adludio stores this information for a period of time following the conclusion of the offering for both archival and legal reasons.
• The use of such information by the applicable client seeking such information will be governed by such client’s privacy policy.
• Other than such client, Adludio will not use or sell such information to or for the benefit of any other third party.

Interaction with our Advertising Units and Other Usage Information.
• Adludio uses a proprietary advertising Unit to serve our clients’ Distributed Content.
• This unit can be hosted on a web page, be featured as part of an application or widget, or be embedded within another advertising unit.
• Adludio collects data about a user’s interactions with the unit, such as what Distributed Content has been featured, played or clicked; when it is video, whether playback is paused or stopped, and information collected in relation to the serving and display of Distributed Content, etc.
• Additionally, we may also collect information about the pages you visited at a Participant Site if our unit or Distributed Content is present on the pages, including what site or page you came from, how long you spent on the page, your click activity on the page, etc.
• The usage and interaction data helps us understand and report to our clients about whether and how often an item of Distributed Content is watched and interacted with, whether partially or fully, and in what context, by users across our network of Participant Sites.
• It may also be used to target or re-target relevant advertising or other content to you through involvement of contracted third parties and/or on other sites you visit.
• Adludio may also use this information to determine what Distributed Content to show in the unit by matching usage with historical data that Adludio may have collected and stored using cookie or other technology. (See above section entitled “Third party suppliers or services”).

Sharing and Social Media Features.
• Adludio works with social media tools, services and networks, such as Facebook and Twitter.
• We provide users with both proprietary and branded tools to enable them to share an item of Distributed Content, solicit or refer other users to view Distributed Content, or express or broadcast their opinion about an item of Distributed Content.
• In some cases, the use of these tools will require a user to provide personally-identifiable information.
• For example, a user may send a link for certain content to one or more recipients by email with a personal message.
• Adludio does not use the email addresses, except as necessary to deliver the communication as requested, and does not store the email addresses. If you use a tag, button or sharing feature that is provided by a branded third-party social media service or network, such as the Facebook’s “Like” button, you may be required to log-in to your account or otherwise take steps to access such third party services.
• Such collection, use and disclosure of any information by or in relation to such third party service is subject to its privacy policy, and this Privacy Policy does not apply.
• Adludio uses the information it collects to operate and improve the functionality, presentation, distribution and appeal of the Distributed Content we place for our clients on Adludio’s network of Participant Sites.
• On occasion, this involves sharing raw logs with a client if we ascertain that the information being shared is the same information that such advertising or publisher client was in a position to have collected themselves.
• The information may also be used to improve the relevance of the Distributed Content served to you and other users visiting a Participant Site.
• We also use and share aggregated technical and usage data with our publishers and advertisers in order to provide measurement and analytics on the effectiveness of their ad campaigns and content distribution programs, and to conduct research and analysis, including to test different ways, to improve the experience of users who encounter our clients’ Distributed Content on our network of Participant Sites.
• Adludio uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of the information it collects. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, however.
• Therefore, while we strive to protect our clients’ and users’ information, please be advised that Adludio assumes no responsibility or liability for disclosure of your information due to errors in transmission, unauthorized third-party access or other causes beyond Adludio’s reasonable control.

Personal Data Collection on Adludio

Personal Data is collected on the Adludio site in various instances including, without limitation:

Registration and Use of Unruly Media’s Services.
• If you register to participate in the Unruly Media network as a publisher or an advertiser, we will require you to provide, and we will store, information that identifies you personally such as your name, contact information, and if applicable payment method.
• We use this information for business purposes such as account maintenance, billing, and to operate and provide the Unruly Media services.

Requested information.
• If you submit an inquiry to or respond to a request by Adludio through any “Request a Proposal,” “General Enquiry,” “Credit Account Application Form” or similar function on an the Adludio site, any information you provide, including any contact name, address, email address, telephone number, financial information, etc., will be used by Adludio in order to respond to such inquiry or request and may be archived by us indefinitely for future reference.
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Access to web-based client interface or console.
• A current client in good standing may be required to provide his or her user name and password, which may include or feature personally-identifiable information, in order to access the console, account areas and/or other areas that are accessible only by clients.
• We use user IDs and passwords, in part, to protect your privacy and security. You are responsible for maintaining the secrecy of your unique password and account information at all times.
• You may, of course, decline to share any or certain items of personally-identifiable information with Adludio, in which case we may be unable to provide you with the services or pay you any monies that might otherwise be payable to you.
• Adludio archives any and all information, including personally identifiable information, that may be input in any registration process even if the user refuses or is declined or fails to use or abandons the services provided by Unruly Media.

Note about Childrens’ Privacy:
• Adludio is very sensitive to the issue of children’s privacy.
• Our websites, products, and services are neither developed for, nor directed at, children, and we do not knowingly collect personal information about children under 13.
• If you believe your child has provided Adludio with personally identifiable data by registering or using any offerings at any Adludio site (i.e., sites owned and operated by Adludio, as opposed to a Participant Site over which we have no control), and you would like to have us look into removing the data from our servers, please contact us at info@adludio.com

Where Adludio stores Personal Data

• The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
• It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
• Such staff maybe engaged in, among other things, the fulfillment of your order or the provision of support services.
• By submitting your personal data, you agree to this transfer, storing or processing.
• Adludio will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
• All information you provide to us is stored on secure servers.
• If you are using the Adludio site and providing personal data to Adludio you are consenting to the transfer of this data to a destination outside the EEA.

Use of Information that Clients Provide

• Adludio uses the personal data you provide to respond to your inquiries and requests, and to keep accurate records concerning the services you are requesting through the Adludio site.
• We generally use non-personally identifiable information in aggregated form to help measure the performance and effectiveness Adludio services
• The information that we collect and receive may be used for purposes including:
o to operate and improve our services, including to create interest-based and other use-based advertising segments, to provide more personalized advertisements, to more precisely direct advertising to you and to present offers, products and programs to you on our behalf and on behalf of our business partners
o to fulfill your requests for products, programs, and services
o to communicate with you and respond to your inquiries
o to conduct research about and analyze your use of our services
o to provide reporting to our partners about the performance of our advertising, analytics and other services
• Moreover, information we obtain from third parties about you may be appended to information that we otherwise have about you in order to improve the products and services we provide or for other business purposes.
• Because our services continually are evolving, we reserve the right to use the information that we collect for other legal purposes that are consistent with this Privacy Policy, even if not specifically described herein

Additionally, you should be aware of the following:
• Adludio does not share personally-identifiable information of any clients with other organizations for their marketing or promotional uses without your express consent.
• From time to time, we may use this information to send you samples or other promotions that Adludio decides may be of interest to you.
• To provide web site hosting, maintenance and security, fulfill orders, offer certain functionality, improve our site, and create new site features, we may disclose one or more clients’ information to affiliated companies or other businesses or persons, such as, for example, credit card service providers or cloud or data storage providers.
• Any personally identifiable information a client provides may be associated with technical and usage information that may be collected at the Adludio site in same manner as we may collect such information at Participant Sites (see above).
• We may also combine it with information collected from other sources, particularly in cases where we and our third party partners or contractors may be vetting or investigating a new, existing or prospective client for potential of fraud or other undesirable activities.

Other Information Sharing

• Adludio may disclose one or more clients’ and/or individual users’ information if required to do so by law (or in a good-faith belief that such action is necessary or advisable in order to comply with any laws of any country or region which may assert jurisdiction) or in order to respond to a judicial or other governmental action, order, subpoena, request, demand or warrant.
• We may make such disclosures without providing notice to you.
• Adludio may also reserve the right to disclose one or more clients’ and/or individual users’ information if it is appropriate or necessary in Adludio’s discretion in order to: take precautions against liability; protect against fraudulent, abusive, or unlawful uses; investigate or defend against any third-party actions or allegations (including assisting a client or third party to do so); assist government enforcement agencies; or protect the security, integrity, rights, property, or personal safety of Adludio, its systems and services, as well as its employees, clients or others.
• Adludio may in the future, and shall have the right to implement technology to, collect or share any information, including any client’s or individual user’s information, that we determine to be necessary or advisable in order to comply with a judicial order or to cooperate with government and law enforcement officials.
• There is the possibility that Adludio, or parts of the company or its affiliates, may one day be purchased by, or merged with, another company or otherwise disclosed or transferred as part of a merger, acquisition, debt financing or sale of assets, including in the event of an insolvency, bankruptcy or receivership. In that the case, the acquiring (or merging) company will have access to your information.

Data retention

• We retain information that we collect and receive in non-aggregate form for as long as is reasonably necessary for the purposes for which it was collected, which in many cases is 12 months or less from your last interaction with our products or services, unless a longer retention period is required by law or is necessary in order to comply with regulatory audits, court orders, legal proceedings, or law enforcement requests

Changes to this Policy

• Adludio may update this Privacy Policy from time to time, and so you should review this Policy periodically.
• If there are significant changes to our information practices, you will be provided with appropriate online notice.
• You may be provided other privacy-related information in connection with your use of offerings from Adludio, as well as for special features and services not described in this Privacy Policy that may be introduced in the future.