PRIVACY POLICY

MOBILE APPLICATION END USERS

Effective Date: August 1st, 2020


Your Personal Information is important to Adikteev, SA & Adikteev, Inc (Hereinafter individually and collectively referred to as "ADIKTEEV", “we” “s” or “our”). This Privacy Policy ("Privacy Policy") explains how We use, collect, disclose, transfer and store personal information (individually and collectively, in whole and in part now referred to for convenience in this Privacy Policy as "Personal Information", “Personal Data” or “PI”). We collect Personal Information indirectly through third parties that market, offer and/or operate Applications (the “Customer” and “Prospect”) and are sharing Personal Information of their users with ADIKTEEV to inquire about or retain our advertising services (the “Services”).

ADIKTEEV ACTS AS A SUB PROCESSOR OR SERVICE PROVIDER for the processing of end-users’ data shared by Customers within the context of the Services. (These individuals, including you, are sometimes now individually and collectively referred to for convenience in this Privacy Policy as “User(s)”, “you”, or “your”).  

ADIKTEEV advertising technology collects and uses data to make mobile apps’ advertising more relevant as well as for ad delivery on mobile and reporting purposes. 

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

Our General Contact Information. If you have any questions or comments about this Privacy Policy, the ways in which ADIKTEEV collects and uses your PI described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights this Privacy Policy, please do not hesitate to contact us at:

Website: www.ADIKTEEV.com 

Email: dpo@ADIKTEEV.com

Postal Address: 

ADIKTEEV SA

Attn: Legal Department 

29 rue des Pyramides, 75001 Paris, France


1. Categories and Specific Types of Personal Information.


Personal Information” is information we collect that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular User, household, or device. 

ADIKTEEV does not collect data that directly identify you (such as your surname, first name, email, telephone number, etc.), nor data that is sensitive or that We consider to be sensitive (e.g. health data, your precise geolocation data, data that reveals your ethnic origin, your political opinions, your religious or philosophical beliefs or your trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, or data concerning your sex life or your sexual orientation).

We collect the following categories of Personal Data : 

  • Identifiers: Mobile advertising ID
  • Commercial information: purchases made by this Mobile Advertising ID on our Customer’s Application(s)
  • Internet or other electronic network activity information: visits on the customer’s application(s), non-precise location of devices 


2. How ADIKTEEV Collects Personal Information.


ADIKTEEV collects information about You:

  • indirectly from our Customer when you visit a Customer's Application, and/or buy an item of the said Application;
  • indirectly from third party data providers when we purchase advertising space to run advertising campaigns ordered by our Customers through real-time bidding (“RTB”); 
  • indirectly from tracking partners - processors of our Customers - such as listed at help.ADIKTEEV.com.


3. How ADIKTEEV Uses Personal Information. 


Regarding end-users, ADIKTEEV may use - as a service provider - Your information and Personal Information that it is provided with to:

  • filter ad delivery to a mobile advertising ID according, but not limited, to the app usage, interests, location or device;
  • deliver interest based advertising on apps; 
  • prevent displaying ad to the same user too many times; 
  • Performing services on behalf of a business or service provider with whom we have a relationship including but not limited to, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
  • Undertaking internal research for technological development and demonstration; 
  • Carry out short-term, reasonable internal purposes related to our Services or your ongoing relationship with us;  
  • Track Users purchasing habits of Services, and perform other analytics.

ADIKTEEV will aggregate your data in order to (i) train, optimize and adjust our advertising tools and Services measure and (ii) analyze the performance of advertiser’s advertising campaigns to provide them with reports and assist them in optimizing metrics. 

In addition, in order to be able to deliver targeted advertising campaigns or personalized commercial offers, we use a real-time bidding system that allows us to acquire advertising space within mobile applications where the campaigns are broadcast. The Personal Information of mobile users may therefore be processed within the framework of this real-time bidding system.


4. How ADIKTEEV Shares Your Personal Information. 


We will not sell your Personal Information to a third party or allow a third party to use the Personal Information we provide for its own marketing purposes. We may disclose your PI to a third party for a Business Purpose. A “Business Purpose” is defined as the use of PI for the business’s or a service provider’s operational purposes, or other notified purposes, provided that the use of PI is reasonably necessary and proportionate to achieve the operational purpose for which the PI was collected or processed, or for another operational purpose that is compatible with the context in which the PI was collected. When we disclose PI for a business purpose, we enter into a writing agreement with that third party that describes the purpose and requires the recipient to both keep that PI confidential, and not use it for any purpose except performing the contract. 

In order to provide the Services, we need to share data (including personal information) with third party vendors, service providers, contractors or agents who perform functions on our behalf, including the ones listed below. Our service providers are authorized to use the information we provide only as necessary to provide these services to us.

We may share information about you:

  • With Affiliated companies (such as our subsidiaries and other companies owned and/or controlled by or affiliated with, ADIKTEEV) who may only use the Personal Information for the purposes described in Section 3 above;
  • With Authorized members of personnel (employees or freelancers of ADIKTEEV) when justified by their activity and subject to a writing agreement. Such employees and freelancers are required to respect the confidentiality of your information.
  • To protect the rights, property, or safety of others, investigate fraud, respond to a government request; or, as needed to support auditing, compliance, and corporate governance functions; and,
  • With Third party hosting and data center providers to store data.

We may also disclose information about You that is not personally identifiable. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our Users.


5. Additional Disclosures for California Residents.


CCPA” means the California Consumer Privacy Act of 2018, as amended (Cal. Civ. Code §§ 1798.100 to 1798.199), and any related regulations or guidance provided by the California Attorney General.

In the preceding twelve (12) months, we have disclosed the categories of PI mentioned in the article 1 for a business purpose. 

In the preceding twelve (12) months, we have not sold PI for a business purpose.

Advertisers (and their intermediaries) that work with Adikteev should include a “Do Not Sell” link on their apps to comply with the CCPA. 


6. Your Rights and Choices.


In Our quality of service provider, with regards to the end-users, if a user of our Customer opts out of the sale of their Personal Information with the Costumer, upon notification from the Costumer, ADIKTEEV will comply with the end-user’s demand by not processing data on behalf of the Customer.

If We receive a request to know (request to access) or a request to delete from an end-user, or any other requests regarding its rights under the applicable regulation, such as CCPA or the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), We will notify the end-user that We are acting as a Service Provider and invite the end-user, to directly contact our Customer, meaning the relevant advertiser or the Application, to exercise its rights. However, if necessary and to the extent provided in the Data Processing Agreement between ADIKTEEV and such Customer, We will assist the Customer in the fulfillment of its Privacy obligations. 

7. Opt-Out from Adikteev Personalized Advertising 


If you want to opt-out of the use of information about your mobile app activities to serve ads that are targeted to your interests using the settings available on your mobile device.

For information about how to opt out on your android device, please click here.

For information about how to opt out on your IOS device, please visit this page.

If you wish to opt out on multiple devices, you must repeat the process on each device. 

Please note that opting-out from targeted ads does not mean you won’t receive ads anymore but that ads won’t be based on your interests.


8. Security of Personal Information.


ADIKTEEV has implemented an information security program that contains administrative, technical, and physical controls designed to reasonably safeguard Personal Information. For example, we use industry-standard encryption technology to secure PI when it is being transmitted over the Internet. We also use industry-standard security strategies for password encryption, security certification, periodic vulnerability testing, and periodic service, database, and server security scanning and vulnerability patching. When our employees need to access your PI in the course of providing Services to you, we track it internally. When our third-party providers, like our credit card processing provider, need to access your PI in the course of providing our Services, they can only do so with a password we’ve provided them for this purpose. However, despite our security program and procedures, you acknowledge and understand that WE CAN’T GUARANTEE that any person or company will be prevented from obtaining your PI, or any other information including but not limited to, through unauthorized means such as cyberattacks or hacking. 


9.Personal Information Retention


We keep your Personal Information for as long as reasonably necessary for the purposes set out in our notices (as defined in Section 3 above).


ADIKTEEV will use and retain your Personal Information for a period of time not exceeding the greater of:

● the Customer has informed us on the withdrawal of the user’s consent;

● the delivery of interest-based advertising campaigns implemented on behalf of advertisers so as long as the Customer has appointed us to deliver our service; 

● as agreed with the Customer, 12 months from the date of the transfer of PI to Adikteev.


10. Privacy Practices of Third Parties.


WE ARE NOT RESPONSIBLE and do not monitor the internet or other practices of any third parties. Our affiliates, business partners, merchants or service providers may have their own privacy policies too. We encourage you to READ CAREFULLY and be familiar with the privacy policies provided by these other parties prior to providing them with any information or taking advantage of any of their offers or promotions. ADIKTEEV IS NOT RESPONSIBLE for the privacy or security of any information you provide to these third parties.


11. International Transfer 


Personal Information we collect may be transferred to, used, and stored in EEA, United States or other jurisdictions in which ADIKTEEV, our affiliates, or service providers are located; these locations may not guarantee the same level of protection of Personal Information as the one in which you live.  By providing us with your Personal Information, you agree to such transfer and/or processing. ADIKTEEV assesses the circumstances involving all cross-border data transfers and has suitable safeguards in place to require that your Personal Information will remain protected in accordance with this notice.  

ADIKTEEV SA is headquartered in France, with an affiliate in the United States. ADIKTEEV has implemented the European Commission’s Standard Contractual Clauses for transfers of Personal Information between our affiliated companies, which require all of our affiliates to protect Personal Information they process from the EEA in accordance with European Union data protection law. We have implemented similar appropriate safeguards where legally required with our third party service providers and partners; details can be provided upon request.


12. Changes to this Privacy Policy.


From time to time, we may update this Privacy Policy at our discretion to clarify our practices, or to reflect new or different privacy practices, or to comply with current laws and regulations. We will post the latest version of the Privacy Policy on this page and indicate the updated revision date.  

We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices.