Privacy Policy

  • AdSublime – Privacy Policy

  • AdSublime (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when we provide our advertising and monetization platform or when we otherwise interact with you, visitors and users of our publisher’s websites and/or applications.

    This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth). In addition to the Australian laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). Appendix 1 below outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.


The information we collect

We may collect personal data when you access any of our publishers’ websites or applications and view our advertisements.

The types of personal information we may collect about you are mainly technical and usage data, and this might include:

  • Internet protocol (IP) address;
  • Device information, as for example the operational system and hardware model;
  • Browser session and browsing behaviour;
  • Advertising identifiers (e.g., IDFA, Google Advertising IDs); and
  • Geo-location data.

If the data exporter provides us, we might process as well demographic information, such as age and gender.

We do not actively request any information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

The information we collect

We may collect personal data when you access any of our publishers’ websites or applications and view our advertisements.

The types of personal information we may collect about you are mainly technical and usage data, and this might include:

  • Internet protocol (IP) address;
  • Device information, as for example the operational system and hardware model;
  • Browser session and browsing behaviour;
  • Advertising identifiers (e.g., IDFA, Google Advertising IDs); and
  • Geo-location data.

If the data exporter provides us, we might process as well demographic information, such as age and gender.

We do not actively request any information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.


How we collect personal information

In general, we do not have direct interactions with you, hence we normally collect your personal information from third parties. This might include:

  • when you use or interact with our publishers or advertising partners, including when you visit their websites and applications; and
  • from third parties, such as from our analytics, cookies and marketing providers, or other business parties that we engage with. See the “Cookies” section below for more detail on the use of cookies

Taking it into account, we normally rely our processing activities related to your data based on the consent you provided to our partners. They have the obligation to provide us any changes you make in your preferences, such as when you withdraw your consent.

Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose your personal information for the following purposes:

  • to facilitate advertisements transactions between advertisers and publishers;
  • for analytics purposes, to operate and improve our business and associated applications;
  • to address fraud, security, and technical issues;
  • to contact and communicate with you about any enquiries you make with us via email or via any website or platform we operate; and
  • to exercise our rights of defence in legal claims, to comply with our legal obligations or if otherwise required or authorised by law.

Our disclosures of personal information to third parties

We may disclose personal information to properly provide our services. Whenever we do so, we carefully choose service providers and business partners that will care about your personal data as much as we do. We may share your personal data with:

  • IT service providers, as for data storage, web-hosting and server providers;
  • Advertising technologies providers, for traffic quality validation, measurement or other relevant services;
  • Advertising partners, including Google, in order to increase the relevance of advertisements for you; and
  • Courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights

Overseas disclosure

Where we disclose your personal information to the third parties listed above, these third parties may also process your personal information outside of Australia. Whenever we do so, we will only disclose your personal information in accordance with the Australian Privacy Principles and the third countries applicable laws.

Your rights and controlling your personal information

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If a third party is providing your personal information to us, they must represent and warrant that they have your consent to provide the personal information to us.

Your choice: We will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You have the right to withdraw your consent at any time. The third parties that provided us with your data have the obligation to communicate us any changes you make in your preferences, such as when you withdraw your consent, and we will take the appropriate steps to respect your choice.

Restrict and unsubscribe: We do not process your data for direct marketing purposes.

Access: You may request access to the personal information that we hold about you. A small and proportionate administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security and do our best to deliver the appropriate standards, we, as any other organization, are still subject to the risks of data processing and cannot guarantee that any incident will never happen. If necessary, we will promptly take action to recover the status and avoid any damages.

In any case, we will retain your personal information only for as long as reasonably necessary to fulfil the purposes we collected it for.

Cookies

Our publishers use cookies on their website, and we use the information collected by them to provide our solutions. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your name or email address. However, they do recognise you when you return to our publishers’ website. It allows third parties, such as Google, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns.

Most of our activities related to cookies are carried out in partnership with Google. To manage the ads served by us through Google and to opt-out from personalized ads from Google, you can use Googles’ Ads Settings page.

Another way of managing your cookies preferences related to online advertising is through different consumer choice tools created under self-regulatory programs in many countries. If you are a resident of the US, you can manage your preferences through the aboutads.info choices page. If you are a resident of the European Union, you can go to Your Online Choices page.

Alternatively, you can also manage your cookies preferences in the browser you are using. You can find below the links to the step by step on how to manage cookies from the most used browsers:

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. If you have any doubts concerning this Privacy Policy or the changes that we eventually applied, please let us know via the email address listed below.

For any questions or notices, please contact us at:

AdSublime

Address: Ajmer, Rajasthan, India

Email: [email protected]

Appendix 1: Additional Rights And Information For Individuals Located in The EU, EEA or UK

Under the GDPR individuals located in the EU, EEA and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights of individuals located in the EU, EEA and UK, as well as information on how we process the personal information of individuals located in the EU, EEA and UK.

Please read the Privacy Policy above and this Appendix carefully and contact us at the details indicated at the end of the Privacy Policy if you have any questions.

What personal information is relevant?

This Appendix applies to the personal information set out in the Privacy Policy above.

In particular, we can process your IP address, device characteristics, device identifiers (IDs), probabilistic identifiers, your non-precise geolocation, your ad profiles and privacy choices. See the “Explanation” column in the table below for more detail.

Purposes and legal bases for processing

We collect and process personal information about you only where we have legal basis for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we use or plan to use your personal information, and which of the legal bases we rely on to do so. Note that we may process your personal information based on more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out below.

By “Publisher” we mean the operator of a website or app (for example, an online game) where you can see our ads or ads of our partners.

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* Instead of legitimate interests, we may rely on your consent to process data in certain cases where indicated by an asterisk above, such as when the operator of the website or app where the ad is shown (that is, the “Publisher”) requires that we can only process your data for the relevant purpose on the basis of your consent.

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use. Further information about your rights is available below.

Legitimate Interests - further information

‍As the table above explains, we may process your personal data based on our legitimate interests (see the rows of the table which mention “legitimate interests” in the “lawful basis” column). 

We carefully assess the impact of this processing on your rights and ensure it does not unduly affect your privacy. We have prepared and documented legitimate interest assessments in respect of each relevant purpose indicated in the table above.

You have the right to object to this processing at any time. Where the table above indicates that legitimate interests are “subject to your right to object", if you have objected, we will not rely on legitimate interest to process your data for that purpose.

To learn more, please contact us directly.

Data transfers 

The countries to which we send data for the purposes listed above may be less comprehensive that is what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes:

  • only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
  • including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU, EEA and UK individuals

You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation. 

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out in our Privacy Policy above.

Compliance with TCF Policies

Our company is committed to protecting your privacy. Therefore, we adhere to the IAB Europe’s Transparency and Consent Framework (TCF), which helps us comply with GDPR and ePrivacy regulations. We comply with TCF’s Policies and Specifications.

We respect your privacy preferences communicated to us through consent management platforms (CMPs).