Last Updated: August 25, 2017.

AdColony, Inc. (f.k.a. Opera Mediaworks Inc.) and its associated business units (“AdColony” or “we”, “us”, “our”) is a technology company that creates and delivers advertisements to mobile devices. This privacy statement (“the Policy”) explains what kinds of information we collect and how AdColony strives to collect, use and disclose information in a manner consistent with the laws of the countries in which it does business. This Policy applies to our advertising platform (the “Platform”) our advertising mediation service (the “Service”) as well as our websites located at  http://www.adcolony.com/ and http://de.adcolony.com (collectively, our “Websites”). AdColony is strongly committed to protecting the privacy of visitors to our Websites and other Internet users (“Users”). If you have any concerns about this Policy, or your privacy when your business or mobile device accesses our Service, please send an email to privacy@adcolony.com and we will try to address your concern.

 

Website Privacy Practices

PERSONALLY IDENTIFIABLE INFORMATION (PII)

AdColony collects personally identifiable information (“PII”) when you choose to provide it to us. PII is any information that specifically identifies or locates a particular person or entity. We receive and store any PII you provide to us. The types of PII collected may include your name, postal address, telephone number, and email address. For example, you may choose to send PII about yourself in an email, by completing an online form on the Websites, or by signing up for our service or e-newsletter. You may also provide us with PII in order to setup an account with us. AdColony uses this information for our reasonable business purposes, including to contact you to respond to your inquiry, to provide the service requested or to maintain your account with us. We may share Client PII with partners such as SSPs as necessary to facilitate the Service. Once obtained, AdColony will store your PII for as long as needed to provide services and for a reasonable time thereafter for record keeping purposes.

NON-PERSONALLY IDENTIFIABLE INFORMATION

AdColony also collects non-personally identifiable information (“Non-PII”) from our Websites. Non-PII is pseudonymous information that cannot by itself be used to specifically identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to the Websites, the referring URL and your computer’s operating system. We may use a third-party analytics provider to help us collect and manage this data. We use this information to help manage and improve the Websites.

COOKIES

We may utilize “cookies” to automatically collect information about visitors to the Websites. Cookies are alphanumeric identifiers that reside within your browser and that allow us to recognize your browser and tell us how and when pages on our Websites are visited and by how many people. Our cookies do not collect PII. You may be able to change the preferences on your browser to prevent or limit your computer’s or mobile device’s acceptance of cookies, but this may prevent you from taking advantage of some features of the Websites. We may also collect information on our Websites using Web “beacons.” Web beacons are electronic images used on the Websites or in our emails. We use web beacons to deliver cookies, count visits, understand usage and activity on the Website and to tell if an email has been opened and acted upon. For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/cookies/.

CONTROLLING OUR USE OF THE PII COLLECTED VIA THE WEBSITE

You can always opt not to disclose PII to us, but keep in mind some PII may be needed to take advantage of some features of the Websites. You may request deletion of your PII by sending an e-mail to privacy@adcolony.com.

 

OVERVIEW OF ADCOLONY’S PLATFORM & SERVICES

AdColony provides an advertising technology platform (our “Platform”) and advertising mediation service (our “Service”) to connect mobile application publishers (collectively, “Mobile Apps and Sites”) with advertisers. Our Platform facilitates the efficient serving of advertisements on Mobile Apps and Sites by collecting information across multiple non-affiliated Mobile Apps and Sites. Our Platform and Service obtains information from Mobile Apps and Sites in order to deliver, tailor and report on the ads being run across our advertising network and Platform by advertisers (our “Clients”).

 

INFORMATION COLLECTED BY OUR TECHNOLOGY PLATFORM

In the course of running our Platform and Services, we collect information from Mobile Apps and Sites and use such data for a number of purposes.

  • Our technology Platform collects and uses Non-PII, including but not limited to: the name of the Mobile Apps and Sites on which the advertisement is served, the IP address used to access the Internet, device identifiers (e.g, Android Advertising ID), the type of phone or other mobile device used (e.g., iPhone, iPad etc.), the operating system (e.g., iOS), the date and time a particular ad is served, whether one of the ads we facilitate was delivered and, if applicable, a record if that ad was “clicked” or if it originated a follow-up action to a third party e.g, “conversion” event. We also collect Non-PII to help us optimize and/or refrain from advertising for a Mobile App that is already downloaded onto a device.
  • Our technology Platform also collects and uses location data about a device from Mobile Apps and advertising exchanges and may match the device location to certain residential or commercial points of interest such as a “household”, “neighborhood”, “coffee shop” or “Sports arena” for interest based advertising, ad targeting, analytics and market research purposes.
  • We sometimes work with third-party data partners and advertising exchanges to enhance our advertising and targeting capabilities on the Platform. As determined by our partners’ business and privacy policies, we may also receive and retain information from partners’ Mobile Apps and Sites including but not limited to: the current location of the device, third party applications on the device or in use at the time of our advertising transaction with the device, the Users age, gender or other demographic indicator, and we may use or derive PII obtained from third parties such as street address to help match data sets, although such PII is processed outside of our Platform.
  • We also collect Non-PII over time and across multiple Mobile Apps and Sites and use Non-PII to provide reports to advertisers and others and to help us display advertisements that may be of interest to Users. Based on the privacy rules of the site or application owner and their business agreement with AdColony, we may integrate this Information with that acquired from other Mobile Apps and Sites. This information is then used to deliver advertisements and promotional information to the specific device identified based on the User’s online behavior or interests. This activity, called online behavioral advertising or interest based advertising, is currently limited to Mobile Apps.
  • We may use, supplement and share Non-PII collected on the Platform at our discretion for a variety of business purposes. Because our services are continually evolving, we reserve the right to use the information that we collect for other legal purposes that are consistent with this Privacy Policy, even if not specifically described herein.

AdColony complies with the Digital Advertising Alliance (DAA) Self-Regulatory Code.

CHOICES REGARDING AD TARGETING AND DATA USE

AdColony offers multiple choice mechanism that enables Users to opt-out of AdColony’s use of information for interest based advertising as well as certain uses of precise location. We do not currently respond to browser based Do Not Track signals. Please note that you will continue to receive advertising after you opt-out, but it may not be tailored to your interests. Please also note that our opt-out mechanism is browser and device specific. Therefore, if you use multiple devices you will need to perform the opt-out operation for each browser or device. Certain devices and device configurations may prevent our opt-out from operating correctly.

Opt-out from our interest based advertising services on mobile apps. We honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For devices where we are able to see that such a selection has been made, we will not track your future activities for the purposes of serving interest based advertising.

Precise Location Choices. If you’d like to adjust your choices regarding the use of precise location data by third parties such as AdColony, you may do so via your device settings. For your convenience, we provide links to instructions for both Apple iOS and Android devices. Also, most mobile applications that collect precise location information offer mechanisms to control the collection and use of precise location information. Please note that these choice mechanisms won’t impact previously collected precise location information.

Opt-out from our partner’s interest based advertising services. Many of our partners that enable targeted advertising are members of one or more digital advertising industry self-regulatory programs. You may click below for the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”) opt-out tools to learn more about targeted or interest based advertising and to opt out of certain targeting programs.

http://www.networkadvertising.org/choices
http://www.aboutads.info/choices/

HOW WE SHARE INFORMATION ONWARD TRANSFER OF DATA

AdColony may share information with trusted third-party partners. These third party contractors are prohibited from using the information for purposes other than performing services for AdColony.

The company may share Non-PII data collected via our Platform. For example, we provide our Clients with information about how many Users view or click the advertising served using our Platform. Similarly, we may share some Non-PII with the Mobile Apps and Sites on which we serve ads in order to optimize and report on the delivery of those ads. This information cannot be used to contact or identify any person individually, but may be considered personal data in some jurisdictions.

AdColony 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. AdColony may also disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

Finally, AdColony may transfer information, including any personally identifiable information, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If AdColony is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a notice on our Websites of any change in ownership or uses of your PII, as well as any choices you may have regarding your PII.

In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, AdColony is potentially liable.

Consent to Worldwide Transfer and Processing of Personal Information – PII given to AdColony may be processed by AdColony in all countries in which AdColony operates or in which its affiliates and partners operate. Each of these countries has different privacy laws that afford varying levels of protection for your Personal Information. Regardless of the laws in place in these countries, AdColony will treat the privacy of your information in accordance with this Privacy Policy. With exception of persons located in the EU and Switzerland, by providing your Personal Information to AdColony, you consent to AdColony transmission to, and processing of your information in, any jurisdiction, in accordance with this Privacy Policy.

Security – The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. However, due
to the inherent nature of the Internet as an open global communications means, we cannot guarantee that your information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely secure from intrusion by others, such as hackers. If you contact us by e-mail, a “contact us” or a similar feature on our Web site, you should be aware that your transmission might not be secure and that a third party could view information you send by these methods in transit.

Children – AdColony adheres to the Children’s Online Privacy Protection Act. We do not knowingly create nor use any interest based advertising segments of children under 13 as part of our Services. Our Website is not directed at children under the age of 13. If we are made aware that we have received PII from someone under 13, we will use reasonable efforts to remove that information from our records.

Access – You have a right to access to your Personal Information and you may update, correct, or delete your account information and email preferences at any time by logging-in to your account and changing the information on file or by e-mailing AdColony at adsupport@adcolony.com with your request. To protect your privacy and security, we take reasonable steps to verify your identity before granting Users profile access. Similarly, if you’ve provided us with PII via the Websites, you may send us an email at privacy@adcolony.com  and we will respond within a reasonable time.

Data Integrity, Purpose Limitation  We 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, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

Data Retention – We store PII such as email address, telephone number or billing details for so long as you continue to have a business relationship with AdColony and for a reasonable time thereafter for record keeping purposes. You may ask us to delete that information by following the instructions below. Where we store PII obtained from Client CRM files as described above, we use and retain such PII only as directed by our Clients. We store pseudonymous information such as device identifiers and cookie IDs so long as our systems continue to encounter a particular User. We store information collected via our Service for up to three years after which time this information gets archived.

Privacy Shield – AdColony complies with the EU-US Privacy Shield and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  AdColony has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. We are subject to the investigatory and enforcement powers of the FTC with respect to our adherence to Privacy Shield. If there is any conflict between the policies 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 page once it is available, please visit https://www.privacyshield.gov.


CHANGES TO THIS PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles and other privacy requirements. When we do, we will also revise the “Last Updated” section above. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the information we collect.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the AdColony Privacy Office by mail or e-mail as follows:

AdColony Privacy Office
11400 W. Olympic Blvd.,12th Floor
Los Angeles, CA 90064
Email: privacy@adcolony.com

 

ENFORCEMENT, PRIVACY COMPLAINTS BY EUROPEAN UNION AND SWISS CITIZENS

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, AdColony commits to resolve complaints about your privacy and our collection or use of your personal information. Persons located in the European Union and Switzerland who have inquiries or complaints regarding this privacy policy should first contact us at privacy@adcolony.com.

We have further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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 www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

DTSG POLICY STATEMENTS 

Digital Trading Statement

AdColony is committed to providing outstanding customer service and brand safety for our clients and publisher partners. We are dedicated to providing complete transparency and control over how brands appear around site content. To achieve this, we set out here our brand protection policy and processes for all campaigns run across our network and our use of campaign white lists according to your instructions. AdColony operates with premium inventory on Mobile Web and Apps with identified publishers containing appropriate content.
AdColony offers ad placements across a secure list of premium vetted mobile websites and Apps. We work with premium publisher partners, with established reputations, grounded in strong brand values, credibility and trust.
We will run campaigns across our network of brand safe premium sites in conjunction with our internal blacklist criteria and with any blacklist or whitelist requested by the advertiser or their agency. Additionally, when requested, we will remove advertising from any url upon instructions from the advertiser or their agency.

Our Brand Protection Policy

Blacklist policy
AdColony operates a blacklist policy and will not serve any advertisements to any sites containing the following generic categories including but not limited to the headings below:

  • Adult Content
  • Alcohol
  • Hate speech
  • Offensive language
  • Violence
  • Illegal drugs
  • Illegal downloads
  • Adware/Malware

In addition if sites are identified as being inappropriate whilst not falling into the identified categories they will be added to a blacklist to be supplied to any supplier or inventory.

Advertiser and Agency Blacklists and Whitelist

Any blacklist or whitelist supplied by an advertiser or their agency will be used in addition to AdColony blacklist or whitelist for use on specified campaigns or for any stated period.

Takedown Policy

In the event of a client’s advertisement appearing on a mobile website or Mobile App that the client deems inappropriate or unsuitable, AdColony will make every effort to take down the advertisement as soon as possible or within the timescales specified in individual terms and conditions and, if requested, will add that site to our blacklist to be used for any future campaigns for that client.

Ad Misplacement Notification

Any incidents of Ad Misplacement identified by Agencies, Advertisers or Publishers can be notified to adops@adcolony.com . We would be grateful if you could provide as much information as possible including the date, time and App or Mobile Website on which you saw the Ad along with the Brand that was being advertised and the reason why you believe it was misplaced.

The contractual consequences of not taking down an ad in accordance with this policy are evaluated and agreed with the buyer on a case by case basis.