Owner and Data Controller
Trumpet Advertising
900 Camp St. Suite 364
New Orleans, LA 70130
Owner contact email: hello@trumpetadvertising.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Cookies; Usage Data; email address; phone number; first name; last name; device information; gender; date of birth; physical address; username; password; geographic position; VAT Number; company name; profession; country; city; profile picture; screenshots; workplace; Data communicated while using the service; various types of Data; state; number of employees; website.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Tag Management, User database management, Remarketing and behavioral targeting, Managing contacts and sending messages, Contacting the User, Advertising, Handling productivity related activity , Interaction with online survey platforms, Heat mapping and session recording, Interaction with data collection platforms and other third parties, Managing data collection and online surveys and Content performance and features testing (A/B testing).
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Meta ads conversion tracking (Meta pixel) (Facebook, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on this Website. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: US – Privacy Policy.
Google Ads conversion tracking (Google Inc.)
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: US – Privacy Policy.
LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Website.
Users may opt out of behavioral targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information; Trackers; Usage Data.
Place of processing: US – Privacy Policy.
X Ads conversion tracking (X Corp.)
X Ads conversion tracking is an analytics service provided by X Corp. that connects data from the X advertising network with actions performed on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Reach (Reach International)
Reach is an advertising service provided by Reach International.
Personal Data processed: Tracker; Usage Data.
Place of processing: United Arab Emirates – Privacy Policy.
GRAPHINIUM (Graphinium SAS)
GRAPHINIUM is an advertising service provided by Graphinium SAS.
Personal Data processed: Tracker; Usage Data.
Place of processing: France – Privacy Policy – Opt out.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out .
Quantcast Measure (Quantcast Corporation)
Quantcast Measure is an analytics service provided by Quantcast Corporation.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Rocket Fuel conversion tracking (Rocket Fuel Inc)
Rocket Fuel conversion tracking is an analytics service provided by Rocket Fuel Inc that connects data from the Rocket Fuel advertising network with actions performed on this Website.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
User ID extension for Google Analytics (Google Inc.)
Google Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.
Personal Data processed: Cookies.
Place of processing: US – Privacy Policy – Opt Out.
Wordpress Stats (Automattic Inc.)
Wordpress Stats is an analytics service provided by Automattic Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Contacting the User
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: email address.
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name.
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.
Google Optimize (Google LLC)
Google Optimize is an A/B testing service provided by Google LLC ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Google Optimize 360 (Google LLC)
Google Optimize 360 is an A/B testing service provided by Google LLC ("Google").
This service allows the Owner to target groups of Users on the base of their past use of this Website. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Handling productivity related activity
This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.
Google Workspace (Google LLC)
Google Workspace is an integrated suite of cloud-based productivity, collaboration and storage services provided by Google LLC. Gmail or other G Suite services are not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside these services for advertising purposes in any other way.
Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; last name; password; phone number; physical address; profession; profile picture; screenshots; Tracker; Usage Data; username; VAT Number; workplace.
Place of processing: United States – Privacy Policy.
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Heat mapping and session recording
Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Hotjar Recruit User Testers (Hotjar Ltd.)
The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Tracker; Usage Data; various types of Data.
Place of processing: Malta – Privacy Policy – Opt Out.
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Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Website.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Hotjar Poll & Survey widgets (Hotjar Ltd.)
The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Tracker; Usage Data; various types of Data.
Place of processing: Malta – Privacy Policy – Opt Out.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Constant Contact (Constant Contact, Inc.)
Constant Contact is an email address management and message sending service provided by Constant Contact, Inc.
Personal Data processed: email address.
Place of processing: US – Privacy Policy.
HubSpot Email (HubSpot, Inc.)
HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.
Personal Data processed: email address; Usage Data.
Place of processing: US – Privacy Policy.
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Managing data collection and online surveys
This type of service allows this Website to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Hotjar surveys (Hotjar Ltd.)
Hotjar surveys is a survey builder and data collection platform provided by Hotjar Ltd.
Hotjar surveys may use cookies to track User behavior. Users can Opt-Out of Hotjar surveys cookie tracking by visiting this opt-out page.
Hotjar surveys respects the Do Not Track option available in most modern browsers that, if activated, sends a special signal to stop tracking User activity. Users can find more information on how to enable Do Not Track for each supported browser here.
Personal Data processed: company name; country; Data communicated while using the service; date of birth; email address; first name; gender; geographic position; last name; number of employees; password; phone number; physical address; profession; state; Tracker; Usage Data; username; website.
Place of processing: Malta – Privacy Policy – Opt Out.
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Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Cookies; email address.
Place of processing: US – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Website with the LinkedIn advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Remarketing with Google Analytics (Google Inc.)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Twitter Remarketing (X Corp.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Usage Data.
Place of processing: US – Privacy Policy.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
HubSpot Lead Management (HubSpot, Inc.)
HubSpot Lead Management is a User database management service provided by HubSpot, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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StackAdapt
At StackAdapt, in accordance with the privacy policies of the websites they work with, they collect Internet Protocol ("IP") address, browser information, recent search history, and activity on various websites in order to display effective native and video advertisements. Native advertisements are advertisements that are integrated into the content of a given platform, such as a website. Based on the behavior and preferences of the users, StackAdapt seeks to group them into certain categories and display the most relevant advertisements to the users in those categories. StackAdapt strictly follows the privacy policy of the website or other platforms they interact with. For example, they would never collect data from a website user who has opted out of cookies.
StackAdapt uses "pixel tags" and/or "cookies". Pixel tags are small bits of code that provide a method of delivery information on a webpage which allows the operator of the page or a third party to collect the IP address of the users of the page. Cookies are small text files that are stored on the browser of a computer that uniquely identify the browser and provide information to the cookie sender. Many websites send cookies to the browsers that are visiting those sites, and many browsers are initially configured to accept cookies. Users can change the browser settings to refuse cookies or to alert them when a cookie has been placed on their browser. The user can check the browser for details in this regard.
StackAdapt uses the data they collect in order to display advertisements that they believe may be relevant to the user. In seeking to identify relevant advertisements, they use this data to create and refine user segments, to develop and refine algorithms, and to understand better how users' interaction with a website might be of interest to advertisers.
Data Security
StackAdapt employs all reasonable industry standard measures to protect against the unauthorized access, disclosure, modification or destruction of the information they collect and their levels of safeguards correspond to the level of sensitivity of the information. While they are committed to ensuring the security of the information, no protection measure can provide a 100% guarantee of security. Consequently, they do not warrant or guarantee the security of the information.
Sharing Data
StackAdapt shares data with trusted third parties, such as advertisers, when they have agreements with them for their use of services on the StackAdapt Platform. These agreements include clauses that hold their partners to the same high level of privacy protection they apply to the data and to never use the data for any other purpose than what they have committed to.
Disclosure
We never disclose any personal data unless we are required by law and we would only do so having verified the lawful authority of the request, such as to comply with a judicial proceeding, court order, or legal process served on us and to defend against legal claims. We may also voluntarily disclose personal data as allowed by law to prevent fraudulent activities.
Mobile Advertising ID
StackAdapt may use Advertising Identifiers for in-app ad targeting on mobile devices. Mobile operating systems including Apple's iOS and Google's Android provide an option of opting out of targeted in-app ads. To opt out, the user simply navigates to the operating system settings and follows the instructions. We act accordingly.
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Adelphic
Adelphic LLC (“Adelphic”) is a mobile and cross-channel programmatic advertising platform that helps brands meaningfully connect and engage with the right audiences.
This Privacy Policy describes Adelphic’s practices and policies for information they collect through their advertising platform (the “Adelphic Service”). The Adelphic Service is designed to deliver, target and report on advertising messages delivered onto computers, mobile phones and similar devices. Those ads are delivered to those who use those devices (the “Users”).
By advertising through the Adelphic Service, or visiting the Site and/or otherwise using the Adelphic Service, you agree to the terms of this Privacy Policy.
Information They Collect
Personal Information That You Give Them
Adelphic generally does not collect or use personal information about individual Users through the Adelphic Service. When they say “personal information,” they mean individually identifiable information that would allow them to determine the actual identity of and/or directly contact a specific living person, such as an email address or telephone number.
Adelphic collects personal information only when they are contacted directly by an individual through the Site and the individual voluntarily provides personal information to us, such as by submitting a question or registering to use the Adelphic Service. Adelphic does not collect personal information about consumers that receive advertiser offers through the Adelphic Service.
To the extent they receive it, they use personal information only in ways compatible with the purpose for which it was collected, such as to respond to such communications, to complete registration for the Adelphic Service, or to use the Adelphic Service. They take reasonable steps to ensure that any personal information is relevant to and reliable for its intended use. By voluntarily providing them with personal information, you are consenting to their use of it in accordance with this Privacy Policy.
Information Adelphic Collects Automatically
The Adelphic Services collect information about your device and the ads that they deliver onto your device. This data, which is collected passively using various technologies may come from such sources as your web browser or the apps that you use. Adelphic also may obtain the precise location (e.g., lat/long coordinates) of your device and may use that information to target ads. They also combine the information collected across multiple sites and mobile apps in order to create interest segments that help them target future advertisements based upon those inferred interests. This practice is sometimes referred to as behavioral advertising or interest-based advertising. They use this information as part of the Adelphic Services to perform a variety of tasks, such as limiting the number of times a specific advertisement is presented to the same User (frequency capping), providing an advertisement to only certain types of Users, or providing a report to a client on the number of its advertisements that were clicked. Adelphic may share this information with clients, vendors, and other companies that they conduct business with as permitted by law.
Cookies and Similar Technology
In operating the Adelphic Service and Site, Adelphic may use a technology called “cookies,” which are small text files that our Site serve to your browser when you access the Site. Their cookies may collect and store audience segments, help provide additional functionality to the Adelphic Service and Site, and help them analyze usage more accurately.
They may also use an advertising identifier created by your mobile operating system to store information on our servers and later retrieve it to provide the Adelphic Services. The Android Advertising ID and Apple iOS’ IDFA are examples of advertising identifiers. For more information about advertising identifiers, please check the settings of your mobile device. The advertising identifiers provide similar functionality as cookies when used to provide the Adelphic Services.
How Adelphic Uses Information They Collect
Personal Information
Adelphic may use personal information as follows:
Pseudonymous Ad Serving Information
Adelphic uses the pseudonymous information they collect via the Adelphic Service to create audience segments that make advertising delivered to consumers more relevant. This process is sometimes referred to as interest-based advertising. This information is typically associated with the advertising identifier referenced above. This information is used by Adelphic, their clients and partners, including advertisers and publishers, to deliver targeted advertising. In the process of serving an advertisement to a device, Adelphic, or our partners, may decide to serve an ad based on one or more audience segments associated with that device, and the audience segment they believe may be associated with that device. Where Adelphic is able to use this and other information to infer that one browser or device likely belongs to the same User or household, the Adelphic Services may consider those browsers and devices “linked” for purposes of ad serving and interest based advertising This linking process is sometimes referred to as creating a device graph. The data they collect is also used for reporting purposes, to give clients more information about the performance of their advertising campaigns, and to improve performance over time.
Your Choices – Opt Out Process
If you want to opt out from interest based advertising from Adelphic, click here.
You may also opt-out of interest-based advertising from many of Adelphic’s partners at the DAA’s opt-out site.
Access/Correction
Adelphic generally does not collect personal information through the Adelphic Service, and only via the Site when it is provided to them. In most cases, if and/or when Adelphic obtains personal information, it relates to their current or prospective clients and business partners. You have certain access rights to your personal information contained in their systems. If you have submitted personal information through the Adelphic Service or Site and wish to access, correct, or delete this personal information, please contact us at info@adelphic.com.
Children
We do not knowingly target advertisements to children under the age of thirteen (13) nor do we knowingly collect any personal information from children under the age of 13.
Information Sharing
With Adelphic's Clients and Business Partners. The Adelphic Service is used by advertisers, publishers and other companies providing advertising services such as advertising agencies. They may share audience segments with these clients to enable them to deliver targeted advertising and to conduct analytics. Where Adelphic shares information with such third parties, they require them to follow privacy and data security principles and practices that are substantially similar to theirs. When you opt-out of Adelphic services (as described above), they stop sharing interest based advertising data with these third parties.
With Adelphic Service Providers and Vendors. They may employ other companies and individuals to perform services and functions on their behalf.
Adelphic may otherwise share any information it collects:
if Adelphic believes that doing so is legally required;
to protect against harm to the rights, property, or safety of Adelphic, our partners, or the public as required or permitted by law;
if Adelphic is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, as permitted by law and/or contract. Adelphic may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Onward Transfer
Adelphic is a growing corporation with operations in multiple countries. They have developed data practices designed to assure information is appropriately protected. While their primary data centers are in the United States, they may transfer personal information or other information to or from Adelphic offices outside of the United States. If they disclose personal information to a third party or to Adelphic employees outside of the United States, Adelphic requires assurances that any information they may provide to them is safeguarded adequately and in accordance with this privacy policy and the requirements of applicable law. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Principles, respectively, Adelphic is potentially liable.
Information Security
Adelphic is committed to protecting the security of the information we collect. They use a variety of technologies and procedures to protect information from unauthorized access, use or disclosure. However, no digital transmission or form of electronic storage is ever fully secure or error free. Therefore, we cannot guarantee its absolute security. Please keep this in mind when disclosing any personal information to Adelphic.
Data Retention
Adelphic stores personal information such as email address, telephone number or billing details for so long as you continue to have a business relationship with Adelphic and for a reasonable time thereafter for record keeping purposes. You may ask them to delete that information by following the instructions below. They store pseudonymous identifiers such as cookie IDs and mobile advertising ID’s collected via their Services for as long as their systems are able to recognize a particular User and for 90 days thereafter. The pseudonymous ad serving and targeting data that is generally associated with those pseudonymous identifiers is stored on a 90-day rolling basis.
Data Integrity, Purpose Limitation
They process information in a way that is compatible with and relevant for the purpose for which it was collected as described above. To the extent necessary for those purposes, they take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
Recourse, Privacy Complaints by European Union and Swiss Residents
Adelphic complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Adelphic has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Adelphic commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Adelphic at: privacy@adelphic.com.
Adelphic has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Finally as a last resort and under limited circumstances, EU and Swiss individuals with residual complaints may invoke a binding arbitration option before a Privacy Shield Panel.
Adelphic is subject to the regulatory and enforcement authority of the United States Federal Trade Commission (FTC).
DAA Principles
Adelphic is a member of the Digital Advertising Alliance (DAA) and complies with DAA’s Self-Regulatory Program for Online Behavioral Advertising.
Changes to the Adelphic Privacy Policy
Adelphic will maintain personal information in accordance with this privacy policy. If Adelphic decides to change this privacy policy, we will post the changes on this page and revise the “Last Updated” date above. Any changes to our Privacy Policy will become effective upon our posting of the revised Privacy Policy on this page. Use of the Adelphic Service or Site following such changes constitutes your acceptance of the revised Privacy Policy that is in effect.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Website, if not stated otherwise within this document.