1. Who are we?
Smart AdServer (“Smart”, “our”, “us”, “we”) is an ad monetization platform, Supply Side Platform (“Platform”) providing programmatic buyers with exclusive access to high quality premium publisher (“Clients”) inventory.
2. What data do we collect and for what purposes?
Information you provide to us
We use this information to respond to the request you may have submitted to us through the contact form. We will only use it to (i) contact you in order to answer your request, (ii) redirect your request to the competent team and (iii) properly qualify your request.
We may also use such information for marketing purposes if you have subscribed to our newsletters and other promotional emails. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these communications.
In addition, if you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses.
If you decide to subscribe to our services, we will use the information below in order to handle your account, and may request additional information such as other contact information and billing account information. We will use such information to operate and improve our Website and services such as to provide notices about your contract, information in connection with our services, to fulfill your service request, to request your feedback or conduct research.
To fulfill the above mentioned purposes we may ask you to provide your:
- name and surname;
- email address;
- job title;
- company and type of company;
- IAB segment;
- phone number.
Information we collect automatically
When using or interacting with our Website, we may also automatically collect and use certain information and Personal Data from your device regarding your browsing experience on our Website.
3. On which grounds do we process Personal Data?
We collect Personal Data from you where we have your consent to do so (e.g. through a check box). Your consent is securely stored and documented in our systems. You may withdraw any consent to personal data processing at any time by sending an email to: firstname.lastname@example.org specifying your request.
You may also unsubscribe from our newsletter and external communications at any time by following the instructions contained in such communication.
We may rely on our legitimate interests if we consider your privacy interests do not override this interest. This legal ground can intervene in our sales and marketing purposes. You can always choose to object to the processing of your Personal Data.
4. To whom do we provide your Personal Data? Who can have access to your Personal Data?
We may share information, including Personal Data, with our affiliates, which include entities controlling, controlled by, or under common control with Smart, and trusted third parties that provide certain services for Smart, such as hosting and CRM tools (e.g. Salesforce).
We may also disclose information if:
- we are required to do so by national or international law or legislation to do so;
- we must comply with an valid or legitimate request or demand;
- such a disclosure is necessary in the framework of the defense of our own rights and/or interests.
5. How long do we store your Personal Data?
The Personal Data you provide to us is stored for the duration strictly necessary to fulfill its purpose stated above (e.g. answer to your request, send you newsletters, duration of the contract). In any case, we will keep your data for a maximum duration of three (3) years starting from your last contact with us.
6. Your GDPR rights
You may ask us at any time:
- Access right: to confirm your Personal Data is being processed and/or to provide you a copy of your Personal Data;
- Rectification/modification right: to rectify your Personal Data if it is inaccurate or incomplete;
- To make an opt-out to the deposit of cookies and to the treatment of your Personal Data by this way;
- Right to erasure: to erase your Personal Data; consent;
- Right to limitation: to restrict the processing of your Personal Data, (i) if the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending;
- Portability right: to provide you with an electronic file of your Personal Data, or to transfer your Personal Data to a third party, if technically feasible.
Your request should be addressed to email@example.com. We will respond within one month. We may extend the response period to two months if such is necessary due to the complexity and number of requests. We will notify and explain the reasons of any extension to you. If we deny your request, we will inform you of the reasons of such denial.
If you consider your rights have been infringed upon according to the current privacy regulation, or regarding the denial of a request, you may lodge a complaint towards your local competent supervisory authority.
7. Your CCPA Privacy Rights
CCPA Personal Information (“CCPA PI”) is defined by California law as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households.
For information on the categories of CCPA PI we collect, the sources from which the CCPA PI is collected, the purposes of collecting those CCPA PI and with whom we may share those, please refer to the sections above.
If you are California resident, the CCPA grants you several rights:
- The Right to request disclosure of CCPA PI we collect, use, share or sell about you
We are committed to ensuring that you know what information we collect, for more information please refer to the ‘what data do we process’ section above or contact us directly at firstname.lastname@example.org.
- The Right to request the deletion of your CCPA PI
Upon your request, we will delete the CCPA PI we have collected about you, except for situations when that information is necessary for us to: provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.
- The Right to Opt-Out of ‘Sales’ of CCPA PI.
We do not proceed to the sale of your CCPA PI collected when you are navigating on our website. For more information on how we use your CCPA PI please refer above or contact us at email@example.com.
- The Right to Non-Discrimination for the exercise of a Consumer’s Privacy Rights
You may however opt-out and/or request the deletion of your Personal Information we process for our own benefit by directly requesting us.
8. Transfer of Personal Data outside of the European Union
Personal Data may be transferred to our affiliates or a partner located outside the EU/EEA including to third-countries for which the European Commission has not adopted an adequacy decision yet. With these partners, we ensure that appropriate safeguards are implemented to ensure an adequate level of protection including but not limited to the signature of standard contractual clauses adopted by the European Commission.
For avoidance of doubt when and if transfer to partner are realized, this is not for commercial purpose nor for monetary or other valuable consideration.
9. How do we ensure the security of your personal data ?
In order to ensure and maintain the security of your Personal Data, we have implemented all technical and organizational measures at our disposal to prevent your data from being unintentionally and accidentally lost, used, altered, or made available to the public without your authorization.
Should such an event occur, we have implemented measures to react promptly and to inform you and the competent supervisory authority when necessary.