Who are we?
Smart (“Smart”, “our”, “us”, “we”) is a fully transparent ad monetization platform, Supply Side Platform (“Platform”) providing programmatic buyers with exclusive access to high quality premium publisher (“Clients”) inventory.
What data do we collect and for what purposes?
- Information you provide to us
Certain pages of our Website may ask you to provide us with the following information, including Personal Data, voluntarily:
- name and surname;
- email address;
- job title;
- company and type of company;
- IAB segment;
- phone number.
We use this information to respond to the request you may have submitted to us through the contact form to request a demo or the contact form to report low quality ads. We will only use it to (i) contact you in order to answer to your request, (ii) redirect your request to the competent team and (iii) properly qualify your request.
We may also use such this information for marketing purposes if you subscribed to our newsletter 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 above 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, to fulfill your service request, to request your feedback or conduct research.
- Information you provide 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.
Specifically, the Personal Data we collect may include your IP address and advertising ID, the latter being a unique identifier attributed to your device. We may collect other information concerning your device such as your browser type, device type, location data (as derived from the IP address), advertising ID, language and other technical information. We may also collect information about how your device has been interacting on our Website, including the pages accessed and links clicked.
This information may be used to maintain our Website and tailor it to your needs. It enables us to better understand how visitors are using and interacting with our Website, where they come from, and what content on our Website is of interest to them.
The following cookies can be found on our Website:
See the chart below for the type of cookie and its purpose
These cookies are essential in order to enable you to navigate our Website and use its features.
These cookies collect anonymous information on how visitors use our Website. For example, we use these cookies to help us understand how visitors arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation and marketing campaigns.
These cookies remember choices you make such as the country from which you visit our Website and language. They can then be used to provide you with an experience more appropriate to your selections and to make the visits more relevant to you.
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign
These cookies enable visitors, if they wish, to login to their social media accounts and share content from our Website with their friends. These cookies do not allow us access to your accounts or provide us with any confidential information relating to any of your accounts.
Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. However, please note that certain features of the Website may not work if you delete or disable cookies. Moreover, if you delete cookies after previously opting-out of Smart AdServer, you may need to renew your opt-out choice. For more information about opting-out, please see Section 8 below.
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.
We also use Personal Data to fulfill our obligations regarding contracts and agreements with customers, partners and suppliers.
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 chose to object the processing of your Personal Data.
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 AdServer, and trusted third parties that provide certain services for Smart, such as hosting and CRM tools.
We may also disclose information if:
- we are required by national or international law or legislation to do so;
- we must comply with an authorized request or demand;
- it is necessary in order to defend our own rights or interests.
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).
The information, including your Personal Data, we automatically collect when you are using or interacting with our Website is being kept between two days and thirteen months, depending on the cookie storing it.
Once the duration period has been reached, the data is then no longer active. For security and regulatory purposes it is stored in our archive databases in compressed form for a maximum of 36 months.
Your privacy rights
You may ask us at any time:
- to confirm your Personal Data is being processed and/or to provide you a copy of your Personal Data;
- to rectify your Personal Data if it is inaccurate or incomplete;
- to withdraw your consent;
- to erase your Personal Data, for instance if it is unlawfully processed or if you withdraw your consent;
- to opt out the process of any data;
- 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;
- to provide you with an electronic file of your Personal Data, or to transfer your Personal Data to a third party, if technically feasible (portability).
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.
Transfer of Personal Data outside of the European Union
Personal Data may be transferred to a partner located in a third country not providing adequate protection regarding data protection. With these partners, we sign standard contractual clauses adopted by the European Commission to ensure an adequate level of protection.
When Personal Data may be transferred in the United States of America, we ensure that the other party is complying with the Privacy Shield Framework and/or that standard contractual clauses are signed, regarding the collection, use and retention of personal information transferred from the European Union to the United States, respectively.
Opt-out and withdrawing of consent
For the sake of transparency, Smart has adopted a cookie opt-out policy, allowing each Internet user to opt out from our advertising network. This ensures that your browser will no longer be identified by our system. Please note that for us to acknowledge your desire to opt-out, one cookie will be placed on your device in order to ensure the performance of your opt-out. Moreover, this opt-out will only be available for the device on which it was created.
If you wish to opt-out, click here. A blank page will open, confirming the opt-out process has been completed and Smart will no longer place cookies on your computer.
You can withdraw your consent, as the case may be, at any time by sending us an email with your specific request at firstname.lastname@example.org. .