Adkernel Platform Privacy Policy

Effective: May 25, 2018

 

Introduction

Adkernel is a leading provider of the advertising technology that serves networks, advertisers, publishers and agencies to manage their advertising businesses. Our goal is to provide you with transparency regarding how your information may be used by Adkernel or third parties with whom Adkernel maintains a relationship with. In addition, Adkernel has provided an explanation of the choices and control you have with respect to information that Adkernel obtains and/or maintains about you.

 

Privacy Commitment

Your privacy is our significant concern, and we want you to be informed about how we use and protect your information. This Privacy Policy will describe how we collect, share, and use the information we receive from our clients and consumers and describes the options that are available to you. We’ll try to make this all as simple and as transparent as possible, but if you have inquiries, you can contact us, and we’ll be happy to assist. (See “Contact Us.”)

 

Definitions

AdKernel – “Adkernel, LLC”, a Delaware limited liability company with its principal place of business located in New York.

 

Platform – The technology provided to Clients by AdKernel via a non-exclusive license agreement.

 

Client – A network, advertising agency, advertising network, or publisher who utilizes the Adkernel Platform via a license and service agreement.

 

User – An individual who maintains a relationship with the Client and accesses their services [or interacts with advertising served by the Client Platform]

 

User Console – The technology provided to the User of our Client Platform where they can control and maintain their contact record, and other relevant details.

 

Data Subject – The person about whom personal data relates.

 

What does Adkernel do?

Adkernel provides a “whitelabel” technology Platform solution to Clients via a license agreement. Clients who use the Platform do so under their own brand names and domains, while we maintain the physical hosting infrastructure that holds the data and maintain the Platform used by our Clients.

 

We process your information solely as a data processor on behalf of our Clients, and it is up to the Client to determine how long they will store your information on our systems.

 

The Platform facilitates the buying and selling of online media advertising inventory for publishers, advertisers, advertising agencies and advertising networks, and allows for Users to access a User Console for information related to their buying or selling of advertising inventory.

The Adkernel Platform may be utilized to build user segments based on behaviors and online browsing activity. The Adkernel Platform provides no explicit tools for “singling out” or otherwise identifying natural, living persons through a record of activity.  Adkernel makes these profiles anonymous in an effort to comply with the relevant provisions of the Data Privacy laws of the jurisdictions within which we operate. For more information on behavioral targeting in general, visit https://www.networkadvertising.org/understanding-online-advertising.

 

What Information do we collect from Clients and Why?

The Adkernel Platform allows a Client to collect and maintain a record of your registration details (for Publishers and Advertisers accounts sign up data), computer connection and other technical information.

 

 

We collect and maintain data from our Clients’ users as part of the process to help identify potential fraudulent transactions that might otherwise be used to harm advertisers that pay to have legitimate internet traffic directed to their products and/or websites.

Information for Platform Clients

Clients that use our Platform must agree to update their privacy policy and practices to be in compliance with the laws of all countries in which they operate.  Adkernel reserves the right to suspend or otherwise terminate any Clients that are determined to have privacy policies and/or business practices that fail to comply with their legal obligations.

 

Clients shall be responsible for obtaining consent from their Users for the use and access of such Users’ personal information by Client or Adkernel. In addition, if Clients are collecting any sensitive personal information from their Users (including information relating to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexuality), Clients agree to obtain affirmative, express consent from their Users or related third parties for the use and access of sensitive personal information by Adkernel.

Your Rights as a Resident of the EEA (European Economic Area)

If you are located in the EEA, you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, port to another service provider, or object to certain uses of your personal data. If you are a Client, a visitor to Adkernel’s website, or a Client user of Adkernel support services and wish to exercise these rights, please reach out to us using the contact information below.

 

If you are a User of a Client who utilizes Adkernel’s Platform and wish to exercise these rights, please contact the Client with whom you interacted with directly — we serve as a processor on their behalf, and can only forward your request to them to allow them to respond.

 

If you are located in the EEA, we note that we are generally processing your information in order to fulfill contracts we might have with a Client, or otherwise to pursue our legitimate business interests listed below, unless we are required by law to obtain your consent for a particular processing operation.

 

In particular we process your personal data to pursue the following legitimate interests, either for ourselves, our Clients, or other third parties.

 

When we process personal information to pursue these legitimate interests, we do so where we believe the nature of the processing, the information being processed, and the technical and organizational measures employed to protect that information can help mitigate the risks to the data subject.

 

Data Subject Requests and Right to Access

 

If you are an EEA resident, you have the right to access information we may store about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact the Client via their privacy policy contact.

Opting Out of Services

In the event you have provided us with consent to use your information, we will rely on your consent to process such information. You may revoke that consent at any time.

 

If you are a registered user of the Client Platform, you may revoke our permission by visiting Settings->Edit Account->Delete Account page inside your account.

If you have given permission via a Consent Management Platform to a Client or Adkernel, you may revoke your consent within their system.  In the event you have received advertising directly from Adkernel, you can manage your opt out status using the following links

iOS opt-out
Android opt-out

 

Additionally, if you are an EEA resident, we inform you that, as part of Adkernel’s processing functions for its clients, your information may be processed using our data centers in the United States and Singapore.

DATA RETENTION

When you access or otherwise utilize a Client Platform, we will maintain your registration information for our records unless and until you ask the Client Platform to delete this information, or otherwise update said information in your User Console.

 

We may retain other data within our databases related to your internet connection, previous advertisements served to you or other related information that we process on behalf of our Clients.  Unless otherwise required by law or agreement, we may maintain such information for up to six (6) months. After this period, Adkernel maintains and uses such data in an aggregated format for internal analytical purposes to improve its Platform, to comply with its legal obligations, to investigate potential fraud and to provide a record of prior internet traffic as required by contract with its Clients.

 

Children’s’ Online Privacy Protection Act Compliance (COPPA)

 

The Platform and services are intended for general audiences and are not directed to children under the age of 13.  We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us using the information at the end of this policy.  If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate any account linked to such underage minor.

 

How do we protect your information?

Adkernel uses both physical and technical security measures to maintain an accepted industry security standard to protect all data on the Platform from misuse and/or unauthorized access.

Physical Measures of Data Security

AdKernel maintains a private, physical “cloud” infrastructure of hardware to provide the Platform services.  Access to this hardware is secured by twenty-four (24) hour, seven (7) days a week on site guards. Building access is secured by keycard entry into the rooms that store the infrastructure. Access to logs and other sensitive data is controlled and monitored to ensure employees of the Client and Adkernel have a legitimate basis for accessing the data.

Technical Measures

Adkernel encrypts the data sent to and from Client Platforms using the HTTPs protocol.  Adkernel also encrypts any sensitive stored information, and salts and hashes Client and User passwords using industry standard encryption methods.

Data Breach

No method of transmission over the Internet or via mobile device or method of electronic storage is 100% secure.  Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

Third Parties

Third parties may receive information about you as follows:

  1.       Advertisers: We may allow third parties to use Cookies to collect the same type of information for the same purposes as we do. In doing so, we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Third parties may be able to associate the information they collect with other information they have about you from other sources. Additionally, we may share non-personally identifiable information from or about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address) to facilitate the display of targeted advertising. You may be able to limit our sharing of some of this information through your mobile device settings.
  2.        Service Providers: We may rely on third party providers to support or provide some of the services that are available through our Platform, including information about your device and connection. We may also rely on third party providers to perform certain services for us in connection with your use of the Platform, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, and other functions. Third party providers may also share this information with their subsidiaries, joint ventures, or other companies under common control. Some of our web pages utilize framing techniques to serve content to you from our third party providers, while preserving the look and feel of the Platform.
  3.       Aggregate or Anonymous Information: We may share user information in the aggregate with third parties. For example, we may disclose the number of users that have been exposed to, or clicked on, advertisements.
  4.       Business Transfers: We may share information from or about you with our parent companies, subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy. If another company acquires Adkernel, or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.
  5.        Investigations and Legal Disclosures: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (a) is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process or law enforcement requests served on us; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service; or (c) protects our rights, reputation, property, or that of our users, affiliates, or the public.
  6.       Links: The Service may link to third party services, like an advertiser’s website. Except as set forth herein, we do not share your personal information with them, and are not responsible for their privacy practices. We suggest you read the privacy policies on or applicable to all such third-party services.
  7.         Third Party Accounts:  We may also share your information in the following circumstances:

 

 

 

Cookies

We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Platform, third party websites, and mobile applications. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Platform, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

 

The purposes for which we use Cookies in the Service include:

Purpose Explanation
Processes Intended to make the service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an account.
Authentication, Security, and Compliance Intended to prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use Cookies to determine if you are logged in.
Preferences Intended to remember information about how you prefer the service over our Platform to behave and look. For example, we use a Cookie that tells us whether you have declined to allow us to send push notifications.
Advertising Intended to make advertising more relevant to users and more valuable to advertisers. For example, we may use Cookies to serve you interest-based ads, such as ads that are displayed to you based on your visits to other websites, or to tell us if you have recently clicked on an ad.
Analytics Intended to help us understand how visitors use the Platform. For example, we use a Cookie that tells us how our search suggestions correlate to your interactions with the search page.

 

You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the service over the Platform. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. Please note that changing any of these settings does not prevent the display of certain advertisements to you.

 

Changes to the Privacy Policy

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.  The most current version of our privacy policy shall govern how we collect, use and disclose information about you. By continuing to use our services after changes to the privacy policy become effective, you acknowledge any such revised privacy policy.

How to contact us

If you have any questions about this Privacy Policy, you may contact us by mail or email at the following address:

 

Attn: Data Privacy Officer

Adkernel LLC

315 Hudson St, Floor 9

New York NY, 10013

Email: policy@adkernel.com