Who we are
We are Adflare, Adflare FZE, and our websites are hosted under the adflare.com domain name. We are committed to protecting personal data in compliance with all applicable laws, rules, and regulations.
What personal data we collect and why we collect it
Contact forms
We have provided contact forms for you to contact us. We will use the information provided by you only for the purposes of your communication.
Cookies
We use cookies on our websites. For more information, please see our cookies information page.
Service Provision
In order to provide our services, contact you, and create an account on our dashboard, we obviously need a name, email address, password, company name and other such contact details. We will also require payment details and the domain names of any websites (or other properties) you wish to monetize with Adflare.
Domain names and privacy
Domain names are not personal data, however domain registration information may contain personal data linking you to the domain names you own. We recommend that you check with your registrar regarding their privacy policy or their privacy services.
Who we share your data with
We will not share or sell any personal data with third-parties. Only authorized personnel have access to your information to service your account.
In order to be able to provide our services, the domain names you submit to us for monetization will be passed on to our partners for approval review.
How long we retain your data for
Whilst you have an account, or as required to provide services to you and to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
Non personal information will be stored on Google Analytics for 26 months.
What rights you have over your data
You can request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
If you have an account with us, you can edit your personal account information when logged in.
Where we send your data
No personal information will be sent anywhere. They are stored with 3rd party service providers (hosting, data centers) with whom with have agreements regarding data security.
Your Rights
- The right to be informed about how your personal information is being used
- The right to access the personal information we hold about you
- The right to request the correction of inaccurate personal information we hold about you
- The right to request that we delete your data, or stop processing it or collecting it, in some circumstances
- The right to stop direct marketing messages and to withdraw consent for other consent-based processing at any time
- The right to request that we transfer or port elements of your data either to you or another service provider
- The right to complain to your data protection regulator
The personal data collected via the Platform
While Adflare collects certain categories of personal data in the course of delivering an ad to you via the Platform, we do not intentionally collect directly identifiable data such as your name, home address, phone number, or any government identifiers such as your Social Security Number unless you provide such data in connection with any request that you may choose to make directly to Adflare. Instead, Adflare collects certain personal data related to your computer or device through the use of cookies and other similar technologies, as explained below.
We may assign a unique identifier called a Adflare ID to your browser, your devices, such as your mobile device, connected television, or over-the-top television devices (“OTT TV Device“), or other screens you may encounter when we serve an ad to it or when you use it to access a client’s digital properties. Digital Properties include websites, emails, apps (“Digital Properties“). The Adflare ID enables the Platform to determine within a reasonable level of confidence that a browser or devices is the same one with which the Platform has previously interacted. For example, the Adflare ID allows us to determine that a browser or device to which we served an ad on Monday is likely to be the same browser or device for which we observed a purchase on Tuesday. In some cases, based on data we receive from our clients or partners, we are able to infer within a reasonable probability that a particular browser or device should be associated with the same Adflare ID. Where we are able to associate more than one browser or device with the same Adflare ID, we may use this information to deliver targeted ads across multiple browsers or devices. This is sometimes referred to as cross-device advertising.
The Adflare ID can be a cookie ID (a unique ID assigned randomly by Adflare to an unrecognized browser), a mobile advertising ID (a unique ID assigned by the mobile operating system, e.g. Apple ID for Advertising or Android Advertising ID), or an OTT TV Device Identifier for Advertising (a unique ID assigned by an OTT TV provider, e.g., Roku ID for Advertising)).
Your Adflare ID is personal data and is associated with other categories of personal data that we collect about you. These categories include the following:
- Bid Request Data and Impression Data: Adflare receives personal data about you when we have the opportunity to show you an ad on Digital Properties and collects additional data when we deliver an ad. We refer to this data as Bid Request Data and Impression Data. The sources of Bid Request and Impression Data are your browser or device and media supply sources, such as publishers (i.e. organizations who operate Digital Properties) and exchanges or supply-side platforms who display ads on publishers’ Digital Properties. This includes data that may be considered personal data in your jurisdiction such as your Internet Protocol (“IP”) address, imprecise location (e.g., country, region, postal or zip code), browser type (e.g., Chrome or Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); and Internet Service Provider (e.g., Comcast or Verizon). It also may include IDs that our partners assign to your browser or device.
- Pixel Data and Other Client Data: Adflare clients may import personal data to the Platform regarding your interactions with them when you visit their Digital Properties. We may similarly collect personal data when you visit our Website. This includes data that may be considered personal data in your jurisdiction such as the time you visited the site, the page URL, your IP address, your browser type (e.g., Chrome or Internet Explorer), the operating system (e.g., Mac OS or Windows), the type of device you used (e.g. laptop or desktop), and data regarding your activities on the Digital Properties. For example, if you are shopping online for a product, place a product in your online shopping cart, or make an online purchase, the client associated with the website or app may use the Platform to collect that personal data and later show you an ad on a different site or app related to that product. Adflare clients also may use the Platform to collect hashed personal data that does not reveal your direct identity, such as hashed email addresses. The process of hashing is commonly used in digital advertising to convert directly identifiable personal data to pseudonymous personal data. We refer to everything described above as Pixel Data. Clients also may import personal data that they have obtained outside of the Platform, such as segments that our clients create or obtain independently from third-party sources. A segment is a grouping of individuals who share one or more attributes (e.g., “car enthusiast”). These individuals are identified by an online identifier in these segments but are not identified by name or other personal data that directly reveals their identity. Clients also may import personal data that they collect or independently obtain offline, such as personal data regarding a purchase you made in the client’s store. The client’s offline data is first processed by the client or a third party, which removes any directly identifiable personal data, appends a Adflare ID, and transmits the file to Adflare for processing. We refer to this data as Other Client Data.
- Third-Party Segment Data and Other Third-Party Data: We work with audience providers who create and provide us with segments for us and our clients to use for advertising purposes. We refer to this as Third-Party Segment Data. We also receive personal data from third-party partners that allows them and/or us to associate the Adflare ID with those partners’ identifiers (through a process called “cookie syncing”) as well as personal data that associates your different devices with each other. Certain third parties may provide personal data to us regarding video content that you view on television. We refer to this personal data in the Policy as Other Third-Party Data.
- Special or Sensitive Categories of Personal Data: We do not knowingly collect any special categories of personal data about individuals in the EEA, including: personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; personal data concerning your health, sex life, or sexual orientation; and genetic or biometric data. Adflare also does not knowingly collect any data about other sensitive categories such as personal data about children, financial account numbers, insurance plan numbers, and criminal convictions or offenses.
3. How we collect personal data via the Platform
The Platform uses various technologies to collect your personal data.
Personal data we collect from your browser or device
Like most digital marketing platforms, Adflare uses cookies and other technologies to recognize browsers and devices and collect the categories of personal data so that we and our clients can infer your interests, deliver more relevant advertising to you, measure the impact of that advertising, and better understand your digital media usage patterns.
The types of technologies used via the Platform that enable us to identify a computer or device, and enable the Platform to function and serve more relevant ads include:
- Cookies – Cookies are small text files. Adflare uses cookies to uniquely identify an Internet browser. Certain browsers or browser settings sometimes block cookies or prevent them from working effectively.
- Pixels – Pixels are transparent images, iFrames, JavaScript or mobile SDKs that we, our clients, and our partners use to understand how users interact with their Digital Properties.
Personal data we collect from third parties
As described above, we receive personal data from third parties such as our clients and partners, including audience data partners, media supply sources, and exchanges or supply-side platforms. We receive this personal data in a number of ways, including through server-to-server transfers, a process called “cookie syncing” and other client and partner calls to Adflare originating from the browser. We process all of this personal data in the Platform.
4. How the Platform uses personal data
We use the personal data in the Platform to deliver more relevant ads to you on behalf of our clients. We also use the personal data to improve our Platform and the products and services that we provide to our clients and partners, as well as to create new products and services. Below, we have set out a description of specific ways we use various combinations of your personal data in the Platform.
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Segments
As described above, a segment is a grouping of users who share one or more attributes. Where allowed by applicable data protection law and industry self-regulatory associations:
- Our clients may use health-related segments about non-sensitive conditions such as an inferred interest in health and wellness or cough medicine and allergy medications.
- Our clients may use segments based on political information or interests
While Adflare does not knowingly create segments that are based upon what we consider to be sensitive information (for example, we do not create segments of EEA users based on personal data considered to be sensitive in the EEA, such as personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, personal data concerning your health, sex life or sexual orientation, or genetic or biometric data), our clients may use the Platform to process some sensitive data (but excluding sensitive categories in the EEA), which may come from our clients’ Digital Properties or our partners. Adflare may process segments based on demographic information such as race, gender and income range where such is information is not considered sensitive. We take steps designed to ensure that this is done in compliance with applicable laws and self-regulatory guidelines, including through our contracts and policies with our clients and partners, but our clients are responsible for this processing, and any queries should be directed to them.
Automated decision-making and profiling
The Platform uses proprietary algorithms to make decisions about whether or not to bid on opportunities to serve you ads and, if so, how much to bid. The ads you see are the result of client campaigns that specify how much to spend and on what basis to spend combined with the use of our algorithms. The ways in which we use algorithms to determine bid prices may be considered automated decision-making in certain jurisdictions. Additionally, these processes, in combination with client campaigns described below, may constitute profiling in certain jurisdictions.
As explained above, we assign a Adflare ID to your browser or device. Using proprietary technology, we associate data that we collect about you with this Adflare ID and create segments using inferred details about certain of your preferences, behaviors, and demographic information. Many of our clients’ campaigns rely on such segments. For example, if you are browsing a shoe retailer’s website on your mobile device, we may infer that you are interested in buying sneakers and associate that mobile device with a sneaker-buyer segment. If a client subsequently wants to advertise sneakers, the client may choose to target that segment across your devices. If Adflare then receives an opportunity to show you an ad on your computer browser, which has been associated with your mobile device by our algorithm, Adflare’s bidding technology will automatically decide whether to bid and if so what price to bid, based on the data and algorithms outlined above.
The automated processes that we use do not affect your legal rights (such as your right to vote, take legal action, or freely associate with others) or your ability to receive social benefits or obtain citizenship, nor do they have legal effects on you. Also, we do not knowingly process or make automated decisions about EEA users based on any data that falls into special categories in the EEA.
Legal basis for processing
Our legal basis under the GDPR for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we process it. However, we will normally collect personal data from you only where the processing is in our (or a third party’s, such as our clients’) legitimate interests and not overridden by your rights, such as your right to opt out. If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate the Platform and serve you ads on behalf of our clients. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
Sale of personal information
For the purposes of the CCPA, Adflare has sold all of the categories of personal information collected on the Platform for certain processing purposes in the past twelve months
Opt-out and choice mechanisms
Opt out of tailored advertising
If you want to limit the data that Adflare collects about you and want us to not target ads that are based on your interests to your browsers or devices, you may opt out from Adflare tracking and tailored advertising at any time through one of the ways described below. If you opt out, you will still see ads, but those ads are less likely to have anything to do with products or services you care about. With tailored advertising, you receive ads and offers that are more likely to be useful to you.
Your opt-out is only applicable to the Platform and does not opt you out from platforms provided by third-party companies. However, you can opt out from both Adflare and many third-party companies at once; to do so, please see “Other ways to opt out of tailored advertising” below. When you opt out, Adflare will collect data from your browser, app, or device only as needed to honor your opt-out and for limited research and development purposes to improve our browser- and device-recognition technology, which also helps to improve our ability to honor your opt-out. When you opt out, Adflare also stops targeting tailored advertising to the opted-out browser, app, or device.
If you use multiple browsers or devices and wish to limit the data that Adflare collects and do not wish to receive Adflare tailored advertising on any of them, you must opt out from each browser and device individually.
Opt this browser out of tailored advertising (if using a browser)
Your current opt-out status with Adflare in this web browser is:
Other ways to opt out of tailored advertising
You may learn more about tailored advertising and opt out of tailored advertising from Adflare and other online advertising companies that are also members of applicable self-regulatory organizations by visiting their opt-out links:
- NAI (browser) – http://optout.networkadvertising.org/
- DAA (browser) – http://optout.aboutads.info/
- DAA Canada (browser) – http://youradchoices.ca/choices
- European Interactive DAA (browser) – http://www.youronlinechoices.com/
- DAA AppChoices page (mobile) – http://www.aboutads.info/appchoices
Other ways to limit ad tracking in the mobile and OTT TV device application environment
You also may limit ad tracking in mobile app environments on your mobile device as well as on your OTT TV Device. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. The NAI provides additional information regarding opting out on mobile available here and TV streaming devices available here.
Where Adflare receives a signal to limit ad tracking, we will collect data from your device only as needed to honor your choice and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your choice. Where Adflare receives a signal to limit ad tracking, Adflare also will not serve tailored advertising in the apps on your mobile device or OTT TV Device.
Opt out of sale for California residents
When advertising involves the sale of your personal information under the CCPA, you receive ads and offers that are more likely to be useful to you. If you want to stop Adflare’s sale of your personal information under the CCPA, please take the following two steps:
- Opt out of tailored advertising by clicking below (if using a browser that is not already opted out). As mentioned above, opting out of tailored advertising will limit the data that Adflare collects about you, and we will not target ads that are based on your interests to your browsers or devices:
Your current opt-out status with Adflare in this web browser is:
- Contact [email protected] to request deletion of your personal data.
If you follow the steps above, you will still see ads, but those ads are less likely to have anything to do with products or services you care about.
If you use multiple browsers or devices and do not wish for Adflare to sell your personal information associated with any of them, you must follow the instructions above for each browser and device individually.
Questions & Contact information
Feel free to contact us anytime if you:
- Have any questions or feedback about this privacy policy
- Would like us to stop using your information
- Want to exercise any of your rights as set out above, or have a complaint
You can contact us here or if you’d like to, you can write to us at:
Adflare FZE
Creative tower
Fujariah freezone
Po box 4422
UAE
Last updated May 2018 to address the European Union General Data Protection Regulation (“GDPR”), which will take effect on May 25, 2018. This data protection law replaces the 1995 Data Protection Directive (Directive 95/46/EC).
