Afront Privacy Policy

LAST UPDATED: SEPTEMBER 16^th, 2022

1. INTRODUCTION

Advertlab LTD is a digital media company, having its registered address at: suite 7144 6 Margaret Street, Newry, County Down, Northern Ireland, BT34 1DF (hereinafter “Afront”, “We,” or “Us”). Afront is the owner of this Website and provides services to publishers, advertisers and other companies (our “Clients”) that allow them to plan and execute digital media advertising campaigns and measure the performance of those campaigns (the “Services”)

2. APPLICABILITY

This Privacy Policy (hereinafter the “Policy”) explains how Afront collects, uses and shares information from individuals that interact with Website. This Privacy Policy applies to user data collected, stored, or processed by Afront for providing the ad-serving services. Сarrying out such activities, We comply with the legal provisions of the EU General Data Protection Regulation (GDPR) and data protection provisions of other regions where Afront services are in use. For Afront, the protection of personal data is very important, and We strictly comply with the data privacy laws. Our services are intended for the general public and not for children. We do not knowingly collect personal information from users who are considered children under their respective national laws. Privacy Policy is an integral part of the user Terms of Use that should be regarded by You with an equal attention.

3. WHAT IS PERSONAL INFORMATION

According to Art.4 No. 1 GDPR, personal data is any information relating to an identified or identifiable natural person, therefore can be used to obtain personal or factual details about the data subject (such as name, address, telephone number, date of birth or e-mail address). Information that cannot (directly or indirectly) be associated with a natural person, for example, anonymous information, is not apersonal information.

4. INFORMATION COLLECTED FROM END USERS OR OWNERS OF PERSONAL DATA IN THE COURSE OF PROVIDING SERVICES

In the course of providing services to our clients we do not intentionally collect information that reveals your real-world identity, such as your name, address, phone number, or social security number. Our clients may use our services to process some sensitive information, which may come from our clients’ websites and may be processed through our technology without our awareness or control of thereof. Rather we collect data about your computer or device using a number of technologies, the explanation to which you will find below. The information we collect is pseudonymous, generalized, and is not considered to be personal information in the majority of jurisdictions. In some other jurisdictions in which we provide services to our clients, in certain contexts, such information, including Internet Protocol (IP) addresses and other pseudonymous information, like certain unique device identifiers that may identify a particular computer or mobile device (for instance, in European Union) may be considered to be personal information.

Please take notice, that We may work with third party data platforms or applications that may be directly integrated into our technology or used separately, supplementing our technology by us or our clients. It helps to deliver targeted advertisements using our advertising technology more efficiently or it allows our clients to use multiple interfaces and manage data more efficiently. Finally, our clients may use third-party data in combination with your user information to deliver targeted advertisement materials and/or inventory across multiple devices that may ultimately be processed by our technology without our knowledge thereof.

Information that we may process includes:

Information about your behavior on our client’s resources, websites, and platforms: including information about the domain, your referring website addresses, date and time of your visits, page view data, search keywords, visitor activities and actions on publisher’s sites, referring and exit pages, platform type, date/time stamp, geolocation (including city, country, zip code, and potentially geographic coordinates if you have enabled location services on your device), click data, types of advertisements viewed;

Information about your browser: your browser type, languages, browser history etc;

Information about your device: including information about your IP address, device make, device model, device operating system, device operating system version, and data connection type;

Information about your Internet service: including information about which Internet Service Provider (ISP) you use;

Information regarding your interactions with our clients, including your use of our clients’ websites, software, and mobile applications, the websites and applications or other pages on the Internet or other resources our clients operate and control;

Any additional data that is reasonably necessary to calculate a statistical ID in certain cases.

Pseudonymous and generalized information collected by our clients or third parties that may include identifiers (similar to mobile advertising IDs and alike) and interest-based advertising data related to or connected with said identifiers.

YOU SHOULD REVIEW THE PRIVACY POLICY AND TERMS OF USE FOR ANY SITE OR APPLICATION YOU VISIT OR INSTALL TO LEARN ABOUT WHAT INFORMATION THOSE SITES COLLECT FROM YOU, AND HOW THEY USE AND SHARE SUCH INFORMATION. THE INFORMATION IN THIS PRIVACY POLICY MAY NOT REFLECT WHAT AND HOW OUR CLIENTS OR WE COLLECT ON ANY INDIVIDUAL SITE.

5. THE USAGE OF THE INFORMATION

We use the information that we collect about your device to:

• Display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations
• For bidding to serve advertisements and to determine which ads are most effective
• Analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person.
• Avoid showing you the same ads too many times
• Build custom audience segments to enable our customers and partners better target their advertisements and offers
• Improve our Services and assist our customers and partners in improving their products and services
• Detect and prevent fraud, fraudulent traffic or to protect the security of our systems

Cookies: Cookies are a technology that is based on a small-size data files containing a string of alphanumeric characters that usually include a unique identifier and are placed on a visitor’s device or computer. Cookies are usually stored at user’s computer permanently (persistent cookies) or temporally. We use cookies on our clients’ websites in order to operate our technology and collect user information and statistically analyze advertisement preferences.

Tags and Pixels: Tags and Pixels are blocks of code that we and our clients may use to track your browsing on the Internet: from resources to any particular websites or applications to track your browsing behavior. Sometimes web beacons are used for these purposes. They are usually transparent or invisible graphic images, no larger than 1x1 pixel, they are placed on a page or otherwise, Internet resource or sent within an e-mail to monitor the behavior of the user visiting the resource or sending the e-mail. It is often used in combination with cookies. We create and use a unique synchronization system to check the quality of information that we have collected with information that our clients collected independently, and later help our clients or third parties that intend to provide you with targeted advertisements.

Mobile Device Identifiers: Mobile Device Identifiers or Mobile Device IDs are unique identifiers which can be used to identify a mobile device. We may use standard device identifiers, to track your use of mobile applications and to determine if a piece of advertisement inventory has been delivered to a specific user or retargeted, or to determine the frequency of certain inventory for a certain user. Ultimately, passing device’s ID back to advertisers helps us and our clients to improve the quality of advertising and its efficiency.

Software Development Kits: These are blocks of code or algorithm similar to Tags and Pixels that are embedded into a digital resource that allows us to track certain information related to the application use, gathered during the process of utilizing our technology.

Other technologies: Please be aware that we use other technologies, including locally stored objects, to collect user information in order to assist users with the inventory delivery and to provide reporting to our clients or to evaluate the quality of advertisement.

6. WHO DO WE SHARE INFORMATION WITH

Afront may share the information We receive about you as described in this Policy as follows:

• Publishers and Supply Partners. We may share your information with publishers to help them understand how users interact with their apps and sites and advertisements on their apps and sites;
• Demand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings;
• Service Providers. We may share personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include: fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services;
• Disclosures to Protect Us or Others. We may access, preserve, and disclose any information We store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity
• International Data Transfers. Where applicable, we will protect information through other legally valid methods, including international data transfer agreements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

7. THIS WEBSITE AND THE INFORMATION COLLECTED THEREIN

By using the Website, You are accepting the terms of this Privacy Policy.

IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS THIS WEBSITE OR OTHERWISE USE THE SITE, REGISTER AS A PUBLISHER OR ADVERTISER OR ENTER ANY PROMOTION.

Collecting Personally Identifiable Information: For purposes of this Privacy Policy, “Personally Identifiable Information” shall mean any information obtained through your use of the Website. This section does not refer to any information we store, collect, or process using our services.

The Personally Identifiable Information that You must submit in order to register, or to enter into an agreement with us, may include, without limitation, your name, title, company name, mailing/billing address, e-mail address, telephone number, Skype name. To the extent Personally Identifiable Information has been collected from You, You acknowledge that such collection is done on a voluntary basis to enable us to provide you efficient access to our materials and/or inventory, services, promotions, and our other products and/or services.

Collecting Non-Personally Identifiable Information: We automatically collect Non-Personally Identifiable Information when You access and use this Website. This Non-Personally Identifiable Information includes, without limitation, the type of browser that you use (e.g., Internet Explorer, Chrome, Safari), your IP address, the type of operating system that you use (e.g., Windows or Mac OS), and the domain name of your Internet service provider (e.g., Verizon, AT&T).

We use Non-Personally Identifiable Information to help diagnose problems with our server, to personalize your Internet experience, and to identify ways of making the Website better. We also may use this Non-Personally Identifiable Information in the aggregate to analyze Site usage, as well as to offer you products and services. This Non-Personally Identifiable Information is not linked to any Personally Identifiable Information.

IP address: An IP address is automatically assigned to your computer every time you establish a connection to the Internet. Afront advertisement materials and/or inventory uses your IP address to help diagnose problems with our server and to administer our website. When you open an account on Afront advertisement materials and/or inventory, your IP address will be associated with personally identifiable information.

Cookies: We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information You submit while staying on our site. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for You to navigate our Website. A session ID cookie expires when You close Your browser. A persistent cookie remains on Your hard drive for an extended period. You can remove them by following directions provided in your Internet browser's "help" file.

8. TECHNICAL AND ORGANIZATIONAL MEASURES

Afront uses reasonable technical and organizational measures to protect the information it collects about You in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, You agree that we may communicate with You electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify You electronically by posting a notice on our Services, by mail or by sending an email to You.

9. PRIVACY RIGHTS

Afront provides consumers with data subject or consumer rights as and when and to the extent required under such applicable laws.

DATA SUBJECT RIGHTS OF THE RESIDENTS OF THE EUROPEAN ECONOMIC AREA

Our Data Protection Officer can be reached via e-mail: dpo@afront.io or by post using the details provided below:

Advertlab LTD dba “Afront”
Attn: Privacy Officer
Suite 7144 6 Margaret Street, Newry
County Down, Northern Ireland, BT34 1DF

General Data Protection Regulation (GDPR)

General Data Protection Regulation (EU) 2016/679 (GDPR) is a European Union law governing privacy and data protection for all residents of the EU. The provisions of GDPR can be also applied to how data is processed and verified outside the European Union.

GDPR is intended to empower the citizens of the European Union to control their personal information. In accordance with the applicable laws, users are authorized to access and modify their own data held by the companies, which includes data collection, ad tracking, surveys, cookies, location data, and every other bit of a user’s “digital footprint”. Users are also entitled to transmit their personal details to other organizations. The GDPR also enforces companies to determine their in-house data security policies.

We maintain our commitment to protect the privacy of our users and abide by the legislation of all regions we operate in, including compliance with the GDPR.

Taking into account the above, personal data (if any) of our users is processed under the “purposes of legitimate interests” as outlined in GDPR Article 6(1)(f). Such an approach also helps us to fight against fraud and reimburse our contractors and agents. In accordance with the GDPR requirements, we will strive to, at any time, (i) streamline the data handling controls, (ii) specify our relationships with data partners, and (iii) provide the data subjects with an understanding and direct management of the way their personal information is used.

Personal Information: Personal information will be pseudonymized and encrypted to ensure the user privacy. The collected information will be handled for standard cases of use described in this Privacy Policy.

We will, to the best of our ability, make sure that our sub-processors operate in full accordance with GDPR requirements before starting cooperation with them and require such sub-processors to comply with this Privacy Policy and maintain appropriate security to protect user information from unauthorized access or processing, unless we have no ability to do so (for example, where we are sharing information with regulatory authorities or courts). Nevertheless, we cannot be held responsible or liable for the use of any information that a sub-processor may execute, or that is gathered by sub-processors. Whenever applicable, users should acquaint themselves with Privacy Policies of any of the involved sub-processors’ websites.

Data Retention: We will retain the gathered data for the period of the cooperation, but in no case longer than the maximum allowed by the existing legislation, unless You choose to withdraw it Yourself.

Data Protection Rights You Have Under GDPR

If you are a resident of the European Economic Area (EEA), You have certain data protection rights. Afront strives to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

The General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. You (data subject) may send official requests to us regarding Your personal data via email to the following address: dpo@afront.io

At any time, You have the right:

Right of access: the right to be informed of, and request access to, the personal data we process about you;

Right to rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete

Right to erasure: the right to request that we delete your personal data;

Right to restrict: the right to request that we temporarily or permanently stop processing all or some of your personal data;

Right to object: the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;

Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and

Right not to be subject to automated decision-making: the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. Your request will be executed no later than 30 (thirty) days from the initial request receipt but we will do everything possible to process it within the first 48 working hours.

Should a data breach related to Your personal information occur, we will notify a relevant supervisory authority within 72 hours thereof.

DATA SUBJECT RIGHTS OF THE RESIDENTS OF THE UNITED KINGDOM

After Brexit, the UK is no longer regulated domestically by the EU's General Data Protection Regulation (GDPR), which governs processing of personal data from individuals inside the EU. Instead, the UK now has its own version known as the UK-GDPR (United Kingdom General Data Protection Regulation). The new UK-GDPR took effect on January 31, 2020.

Under the UK-GDPR, individuals can exercise: the right to be informed; the right of access; the right to rectification; the right to erasure; the right to restrict processing; the right to data portability; the right to object to processing; the rights in relation to automated decision making and profiling

If you would like to exercise any of these rights (as a resident of UK) , please contact us with a reasonable proof that you are subject to these rights via email to the following address: dpo@afront.io

Please note, as we already stated most information we deal with is anonymized when we receive and process it, therefore, we cannot identify you individually, You need to provide us with some additional information to enable us to identify the user information you are referring to, it may be technologically impossible to identify your information, although we will try to accurately fulfill your request. 

DATA SUBJECT RIGHTS OF THE RESIDENTS OF BRAZIL

Afront comply with the principles and requirements of data processing under the Lei Geral de Proteção de Dados Pessoais (LGPD), including, but not limited to, age-gating requirements. All the data received by using our services is anonymized and therefore falls outside the scope of LGPD.

We hereby inform You about the following rights You have under the LGPD:

Confirmation: confirmation of the existence of processing;

Access: access to the data;

Rectification: correction of incomplete, inaccurate or outdated data; anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of LGPD;

Data portability: portability of the data to other service providers or suppliers of product, at the express request;

Anonymization: anonymization, blocking or elimination of the personal data processed with the consent of the data subjects, except in the events set forth in article 16 of LGPD;

Deletion: You have the right to have their personal data deleted if the processing of that data was based on consent;

Information: You have the right to be informed about sub-processors and other third parties that access or process their personal data. You also have the right to be informed about Your consent choices and the consequences of refusing consent;

Revocation: revocation of the consent, pursuant to the provisions of paragraph 5 of article 8 of LGPD;

Bring complaint: lodging a complaint with the Data Protection Authority;

Opposing the processing of personal data where there is non-compliance with the provisions of LGPD;

Request review: You have the right to request the review of decisions made solely on the basis of automated processing of personal data which affect Your interests. This includes decisions used to define Your personal, professional, consumer and credit profile, or the aspects of Your personality.

If You would like to exercise any of these rights, please contact us via: dpo@afront.io

DATA SUBJECT RIGHTS OF THE RESIDENTS OF CHINA

Afront comply with all the principles and requirements of data processing under the Personal Information Protection Law (the “PIPL”). The before mentioned principles includes among others: accuracy, accountability and security, purpose limitation, collection limitation, openness and transparency, lawfulness and necessity.

We hereby inform You about the rights You have under the PIPL:

You have the right to know, decide, refuse, and limit the handling of their personal information by others unless laws or regulations stipulate otherwise;

You have the right to access and copy Your personal information in a timely manner, except when the laws and regulations require confidentiality;

You have the right to correct or complete inaccurate personal information in a timely manner;

You have the right to request Us to explain Our personal information handling rules;

You have the right to deletion of Your personal information if (i) the agreed retention period has expired, or the handling purpose has been achieved; (ii) We as a personal information handler cease the provision of Our services; (iii) You rescind consent where the processing of personal information was based on Your consent; (iv) the information is handled in violation of laws, regulations or agreements;

You have the right to request Us to transfer Your personal information to another personal information handler.

If You would like to exercise any of these rights, please contact us via: dpo@afront.io

DATA SUBJECT RIGHTS OF THE RESIDENTS OF CHINA OF VIRGINIA AND COLORADO

Afront expresses its willingness to comply with any and all the principles and requirements of data processing under Virginia Consumer Data Protection Act (VCDPA) effective January 1st, 2023, and under Colorado’s Consumer Data Protection Act (CPA) that will be effective on July 1, 2023.

If You have any questions in regard to Your rights under the aforementioned legislation, please don’t hesitate to contact us via: dpo@afront.io

10. DATA RETENTION PERIOD

Afront retains information collected for a period of up to twelve (12) months, unless otherwise required by law or applicable contract. Afront may retain the information it obtains about You as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by You in participation of a survey or opinion-based application by Afront, We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. After the applicable retention period, Afront will only retain and may only use your data: (i) in an aggregated or anonymized format; (ii) to comply with its legal obligations; and (iii) to resolve disputes and enforce agreements. Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.

11. INTERNATIONAL TRANSFERS

Afront may share your information with clients, customers, partners, the Group and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EEA resident, we may share your information with our non-EEA clients or the Group), subject to any contractual or legal requirements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world.

While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take reasonable measures to protect your information in accordance with this Privacy Policy.

12. PRIVACY OF CHILDREN

The Website is restricted to individuals over the age of 18. We do not knowingly collect, maintain, or use Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age, and no part of the Website is directed to children under the age of 13 (and in certain jurisdictions under the age of 16). If you learn that your child has provided us with Personal Information without your consent, you may alert us at legal@afront.io. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.

13. OTHER WEBSITES

Our website and the ads we service may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.

14. CHANGES TO THIS PRIVACY POLICY

Revision to the Privacy Policy: We may revise this Privacy Policy in our sole discretion, so review it periodically. If You continue to visit this Website or use our Services after such changes have been made, You hereby provide your consent to the changes.

Posting of Revised Privacy Policy: We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If You are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

15. CONTACT US

Questions or concerns regarding our compliance with this Policy may be directed to dpo@afront.io or contact us at:

Advertlab LTD
Suite 7144 6 Margaret Street, Newry, County Down, Northern Ireland, BT34 1DF

Afront will address your concerns and attempt to resolve any privacy issues in a timely manner

If You are an EU citizen and feel that Afront is not abiding by the terms of this Privacy Policy, please contact Us at the contact information provided above. If any request remains unresolved, You may contact the national data protection authority for your EU Member State