KontrolAds.com Inc. (“Company”, “we” or “us”) provides advertising technology solutions that enables media companies, online advertisers, and web publishers to buy, sell, and measure the effectiveness of their advertising campaigns. In order to accomplish this, we have created and/or manage certain online (including without limitation via websites and their sub-domains) and mobile applications (“App” or “Apps”), ad serving technology and related support and hosting services. (Such Apps, technology and services are each referred to as a “Service” and collectively as the “Services”).
1. What Information Do We Collect and How Do We Collect It?
At various times, you could be asked to provide information such as your name, email address, contact phone number or other information. Information collected is often defined as being either anonymous or personally identifiable:
“Personally Identifiable Information” refers to information that tells us specifically who you are, such as your name, email address, or phone number. Using the Services may allow us to “recognize” you to allow us to personalize the Services for you.
As is true of most apps and websites, we gather certain information (such as mobile provider, operating system, etc.) automatically and store it in log files. We use this information, which does not identify individual users, to analyze trends, to administer the Services, to track users movements around the Services and to gather demographic information about our user base as a whole. We may link some of this automatically-collected data to certain Personally Identifiable Information.
Personally Identifiable Information
When you register with us via our Services, we may ask you for some Personally Identifiable Information, such as your first and last name, email address, home address, and other information. If you are an advertiser, we need you to provide certain billing information, such as credit card, bank account or PayPal information. If you are a publisher of ads, we need you to provide information about your website and payment method, such as bank or PayPal account information. You may review and update this Personally Identifiable Information in your profile by logging in and editing such information in your dashboard.
If you choose to allow a Service to collect your location data, such location data will be available to us. In addition, if you have an account with Facebook, Twitter, Google+, LinkedIn or other similar websites (each a “Social Network”), your Social Network identity, including your public picture, may be associated with your location data.
If you send a “Do Not Track” request through your web browser, we may still collect and use your browsing data to improve security, to provide our Services and to generate reporting statistics, but in general we will not track other websites that you may have visited.
No Information Collected from Children.
We will never knowingly collect any individual information from children under the age of 13. If we obtain actual knowledge that we have collected individual information from a child under the age of 13, that information will be immediately removed from any access. Because we do not collect such information, we have no such information to use or to disclose to third parties. We have designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
2. How Do We Use Individual Information?
If you contact us by email or by filling-out a registration form, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you.
In addition, we may use the individual information described above to send you promotional communications regarding the Services. If you decide at any time that you no longer wish to receive such promotional communications from us, email us at [email protected] and request to be removed from our list.
3. How Do We Store Your Personal Information?
Storage and Security of Individual Information
The Company operates or leases secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information. Notwithstanding such measures, we cannot guarantee that our security measures will prevent our computers from being illegally accessed, and the individual information on them stolen or altered.
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and individual information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
Third Party Hosting, Serving and Storage
Retention of Information
How long we keep your Personally Identifiable Information depends on the reasons we collected it and how we use it (as described in parts (1) and (2) above), and we do need certain information in order to provide some of the Services to you. If you decide to delete your information, we may cancel your account. We may retain an archived copy of certain records as we believe is necessary for our legal, accounting, and reasonable business purposes or is required by law.
4. Do We Disseminate Any Personal Information?
Publishers and Advertisers
As part of the buying and selling process and related transactions in our marketplace Services, we facilitate the sharing of information, which may include some Personally Identifiable Information, between our publisher and advertiser users who work directly with each other. By using the Services for such transactions, you are directing us to share such information in this way. We expect you to respect the rights of the users whose information you receive and you may not use such information without the express consent of that user except as needed in connection with these transactions.
We may use third parties to help operate and distribute our Services, authenticate users and deliver products and services, and may share limited Personally Identifiable Information with our service providers, vendors, suppliers, and other third parties that provide products or services for or through this Service (such as website or database hosting companies, authentication providers, credit card payment processors, address list hosting companies, e-mail service providers, analytics companies, distribution companies and other similar service providers that use such information on our behalf) ( “Third Party Service Providers”). Unless otherwise stated, these Third Party Service Providers do not have any right to use the Personally Identifiable Information we provide to them beyond what is necessary for them to assist us.
We may disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, our Services to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user or client. For example, aggregated data may be accessed by publishers running our serving technology and the advertisers they work with directly, and our advertisers may access aggregate geographic data for their campaigns.
Complying with Legal Process
We take reasonable steps to ensure the privacy of data uploaded. We reserve the right to use or disclose your Personally Identifiable Information and other information in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise our legal rights or defend against legal claims or in the event you violate or breach an agreement with us. We may use and disclose your Personally Identifiable Information if we believe you will harm the property or rights of Company, its owners, or others.
In the event the Company goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets as well as in the event of a bankruptcy, assignment for benefit of creditors or receivership, your Personally Identifiable Information may be disclosed and will likely be among the assets transferred. You may be notified thereafter via prominent notice on our web site for 30 days of any such change in ownership or control of your Personally Identifiable Information. We further reserve the right to disclose, transfer or sell your Personally Identifiable Information to companies who are affiliated with us in our sole discretion.
5. International Use of the Service and Transfer of Information Outside the European Union
The Services are hosted and operated in the United States and may be hosted and operated elsewhere by us and our authorized Third Party Service Providers. Use of the Services is governed by United States law. If you are accessing our Services while you are domiciled outside of the United States, please note that laws in the United States may differ from laws where you reside, which may include the European Union’s General Data Protection Regulation (“GDPR”).
You acknowledge that the Personally Identifiable Information you are providing us may be collected and stored in the United States and elsewhere and therefore consent to the transfer of information to and storage of the information outside of your domiciled country and in the United States.
If you are in a jurisdiction covered by the GDPR, please note the following: Our legal basis for collecting and using your information depends on what the information is and the context in which we collect it, as described in parts (1) and (2) above. You may access, correct or update certain Personally Identifiable Information as described in part (1) under “Personally Identifiable Information” above. You may remove cookies as described in part (6) below. To request deletion of, withdraw consent to use of or request other restrictions on your Personally Identifiable Information, please contact us as described under part (7) below. We will take reasonable efforts to delete your Personally Identifiable Information upon such request in accordance with the “Retention of Information” section in part (3) above. Please note that withdrawing your consent will not affect the legality of any processing based on legal grounds other than consent or conducted prior to your withdrawal. You also have the right to complain to your local data protection authority about our collection and use of your Personally Identifiable Information, but please contact us first with any concerns. If you need further assistance, please contact us as described under part (7) below.
6. Information About the Technology
Some of the Services may employ cookies to collect non-Personally Identifiable Information in the course of providing clients with ad-serving services, for the purpose of helping clients determine which advertisement is suitable to be delivered to a user, or to maintain a user’s state (keeping them logged in, etc.). A cookie is a small text file that can be stored on a user’s computer when that computer’s browser views an advertisement or website of one of our clients. The cookie is associated with and unique to the specific computer. The cookie does not contain the user’s name, address, phone number, email address, or anything that personally identifies it. We collect into the cookie only non-Personally Identifiable Information such as the type of the computer’s operating system, type of internet browser software, what web pages were viewed and at what time, and geographic location of user’s internet service provider.
Removing Our 3rd Party Ad-Serving Cookie from Your Browser
In your browser’s settings, there should be an option to remove cookies. The domain that we set cookies during your use of our Services is typically KontrolAds.com, syndicateads.net, or the self-service direct instance of the domain name of the Service you are using (such as self service.[domain name].com.