This policy sets out:
- the information we collect about you when you visit our website, use our products or services, or otherwise interact with us;
- how we use, share, store, and secure the information; and
- how you may access and control the information.
In this policy, “Adwerk Pte. Ltd.” or “we” refers to Adwerk of Adwerk Pte. Ltd., 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore (068914), Singapore and “Platform” means our website at https://adwerk.io/ the platforms and ad-networks we are using for our services.
In this policy, “personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of our products or services, that relates to an identifiable individual.
1. What information we collect about you
1.1 We collect the following types of information about you:
- account and profile information that you provide when you register for an account or sign up for our products or services, for example
- Name
- information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);
- content you provide through use of our products or services, for example Display Advertising (collectively, “User Content”);
- communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or a questionnaire that we send you (collectively, “Preference Data”);
- information about your device or connection; for example:
- Event Type (Impression, Click, Type of Conversion)
- Timestamp of Event
- Publisher, GDPR Consent (YES/ NO)
- Device ID (GAID for Google, IDFA for Apple) – Only when GDPR Consent YES
- Geodata (Lat/ Long) of Type of event – Only when GDPR Consent YES
- Information about your use of or visit to our Platform, for example:
- Event Type (Impression, Click, Type of Conversion)
- Timestamp of Event
- Publisher
- Device ID (GAID for Google, IDFA for Apple) – Only when GDPR Consent YES
- Geodata (Lat/ Long) of Type of event – Only when GDPR Consent YES
1.2 We collect the above information when you provide it to us or when you use or visit our Platform. We may also receive information about you from other sources, including:
- our business partners and service providers based in Germany, Austria, Romania for business partners and Denmark and Spain for service providers.
1.3 We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.
2. How we use information we collect
2.1 We only use your personal information where the law allows us to. We use your personal information only where:
- we need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products or services, to provide customer support and personalised features, and to protect the safety and security of our Platform;
- it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests;
- you've given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or
- we need to comply with a legal or regulatory obligation.
2.2 If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us (please refer to paragraph 9. for contact information), but please note this will not affect any use of your information that has already taken place.
2.3 We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.
2.4 For visitors to or users of our Platform who are located in the European Union, we have set out our legal bases for processing your information in the Legal Bases Table at the end of this policy.
3. How we share information we collect
3.1 We share information with third parties that help us operate, provide, support, improve, and market our products and services, for example third-party service providers who provide Audience creation based on Device ID (GAID for Google, IDFA for Apple) – Only when GDPR Consent YES.
3.2 Third-party service providers have access to your personal information only for the purpose of performing their services and in compliance with applicable laws and regulations. We require these third-party service providers to maintain confidentiality and security of all personal information that they process on our behalf and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of your personal information.
3.3 We take reasonable steps to confirm that all third-party service providers that we engage process personal information in the manner that provides at least the same level of protection as is provided under this policy. Where any third-party provider is unable to satisfy our requirements, we will require them to notify us immediately and we will take reasonable steps to prevent or stop non-compliant processing.
3.4 We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.
3.5 If you use any third-party software in connection with our products or services, for example any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.
3.6 Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.
3.7 We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.
3.8 If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.
4. How we store and secure information we collect
4.1 We use data hosting service providers based in Germany to host the information we collect.
4.2 We have adopted the following measures to protect the security and integrity of your personal information:
- information is encrypted using TLS/SSL technology;
- your account is password-protected;
4.3 We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
4.4 While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.
4.5 We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Deletion on request. Maximum storage 120 days.. We periodically review the basis and appropriateness of our data retention policy.
5. How we transfer information internationally
5.1 We collect information globally and primarily store that information in Germany. We transfer, process, and store your information outside your country of residence where we or our service providers operate for the purpose of providing our products and services to you.
5.2 Some of the countries in which our companies or service providers are located may not have the privacy and data protection laws that are equivalent to those in your country of residence. When we share information with these companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of information.
6. Your rights
6.1 You have the right to:
- be informed of what we do with your personal information;
- request a copy of personal information we hold about you;
- require us to correct any inaccuracy or error in any personal information we hold about you;
- request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
- object to or restrict the processing by us of your personal information (including for marketing purposes);
- request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
- withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).
6.2 Our Platform enables you to update certain information about yourself, for example each banner or video as part of the dispay advertising offers the user to remove ID. This goes to Adform DSP and MediaSmart DSP and they request to remove data collected.
6.3 You may opt out of receiving marketing materials from us. How you can opt-out of processing and access or update your Personal Information:
- Website browsing and/or server cookies. You may refuse or accept cookies from websites at any time by choosing the appropriate settings on your browser. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please we aware that should you choose to decline all cookies, you may not be able to sign in or use other features of our website that depend on cookies. Information about the procedure to follow in order to enable or disable Cookies can be found at:
-
Chrome:
https://support.google.com/chrome/answer/95647 -
Safari:
https://support.apple.com/kb/ph21411
&
https://support.apple.com/en-us/HT201265 -
Firefox:
https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored -
MS-Explorer:
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies - For more information about other commonly used browsers, please refer to: http://www.allaboutcookies.org/manage-cookies/
- To opt-out of participating in Google Analytics data follow the instructions: https://tools.google.com/dlpage/gaoptout
-
Chrome:
- Some of our clients have their own opt-out mechanisms that are linked from their sites. You should review the Privacy policies of those companies for these opt-out links, if you no longer wish to receive targeted advertising from a particular company.
-
Interest-based advertising Personal Information You may opt-out of this interest based advertising process altogether Please note that you have the choice to opt- out from all Interest Based Advertising activities by changing the settings on your Android or iOS phone or tablet (we never use your identifiers if you use mobile devices with any other operating system). Your iOS or Android mobile device provides a “Limit Ad Tracking” or “Opt out of interest-based advertising” setting. When you have opted out using this setting on a device, we will not allow our clients to use personal information collected from that device for any targeting purposes, nor to create any user segments. You can find the setting for your mobile device by following the directions below:
- iOS Device iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting iOS 6 Go to your Settings >Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting More information about the iOS setting can be found here.
- Android Device. Android devices with OS 2.2 and up and Google Play Services version 4.0 and up: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising” If you’ve turned on Limit Ad Tracking on your iOS device or the Opt out of interest-based ads on your Android device, you can restore interest-based ads by turning the settings off.
6.4 As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.
6.5 Any request under paragraph 6.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.
6.6 We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.
7. Changes to this policy
We may amend this policy from time to time by posting the updated policy on our Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised policy.
8. Policy towards children
Our products and services are not directed to individuals under 16. We do not knowingly collect personal information from individuals under 16. If we become aware that an individual under 16 has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 16.
9. Contact us
8.1 Please contact us at legal@adwerk.io or submit any written request to:
Adwerk Pte. Ltd.
160 Robinson Road
#14-04 Singapore Business Federation Center
Singapore (068914)
Singapore
Attn: Data Controller
8.2 Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed.
Cookies Policy
Legal bases table
| Processing purpose | Type of data processed | Legal basis |
|---|---|---|
| Event Type (Impression, Click, Type of Conversion) | Technical Data | Contract |
| Timestamp of Event | Technical Data | Contract |
| Publisher | Technical Data | Contract |
| GDPR Consent (YES/ NO) | User Consent | Consent |
| Device ID (GAID for Google, IDFA for Apple) – Only when GDPR Consent YES | User Consent | Consent |
| Geodata (Lat/ Long) of Type of event – Only when GDPR Consent YES | User Consent | Consent |
Last updated: 9th November 2023