ADOGTECH PRIVACY POLICY
Nov 1, 2022
This Privacy Policy explains how AdogTech entities (for purpose of European data protection laws, AdogTech entities providing AdogTech Advertising Service which are subject to GDPR can be viewed HERE , collectively, “AdogTech”, or “we”, “us”, “our”) collect your information through our advertising platform (“Advertising Service”) and our website at www.adogtech.com (“Site” or “Website”). This Privacy Policy is subject to any service agreement between AdogTech and you. By using the Adverting Service or this Site, you acknowledge that you have read and understood this Privacy Policy. Please review this Privacy Policy before using the Advertising Service or this Site. We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. If we make material changes to this Privacy Policy we will notify you by means of a prominent notice on this Site prior to the change becoming effective. Privacy Policy of AdogTech's Website.
1. Introduction
This Privacy Policy of AdogTech’s Website
applies to information collection and use including while you are visiting and
using the Site. For the purposes of European data protection laws, AdogTech is
the data controller of your personal information.
2. What Information We Collect
As you navigate through this Site, some of
your personal information may be actively collected (for example, names, birth
dates, personal ID card numbers, addresses, telephone numbers, E-mail
addresses, occupations, education, work experience and related information) or
passively collected (which you did not actively provide) such as your browser
type, domain name, IP address, pages visited, and the length of your user
session using various technologies and means, such as Internet Protocol
Address, cookies, Internet Tags and navigational data collection. In order to
improve our service quality, it may be necessary to ask for personal
information to fulfill your requests and provide a better service. AdogTech is
entitled to take measures to validate the authenticity of personal information
you provide. If you give us personal information of somebody else, we will
assume that you have their permission to do so. Transmissions to and from this
Site may not be confidential and consequently, may be read or intercepted by
others.
3. How We Use Your Information
The provision of personal information by
you may be necessary where in our legitimate interest for the following
purposes: (i) to provide you with AdogTech products or services or information
in relation to the same; (ii) to sign you up for an event or training; (iii) to
contact you and respond to your requests and enquiries; (iv) for business
administration, including statistical analysis; (v) to personalise your visit
to the Site and to assist you while you use the Site; or (vi) to improve the
Site by helping us understand who uses the Site.
4. Disclosure of Your Personal Information
We may use selected third parties to
provide us with services, including companies that assist with programming and
technical aspects of hosting and operating the Site, who may have access to
your personal information. Our affiliates may also have access to your personal
information including through or in connection with this Site for the purposes
set out in this Privacy Policy. The servers used in the operation of the Site
automatically identify a computer by its IP address. Although, we will not be
able to identify the computer using its IP address once you have left the Site.
If we, in good faith, determine that you have or are attempting to misuse or
harm the Site, we may investigate and cooperate with appropriate law
enforcement agencies to protect our rights or property. Similarly, we may share
your personal information as required or permitted by law to comply with a
subpoena or similar legal process or government request, or when we believe in
good faith that disclosure is legally required or otherwise necessary to
protect our rights and property, or the rights, property or safety of others,
including to advisers, law enforcement agencies, judicial and regulatory
authorities. We may also transfer your personal information to a third party
that acquires all or part of our assets or shares, or that succeeds us in
carrying on all or a part of our business, whether by merger, acquisition,
reorganisation or otherwise.
5. International Transfers
When you are located in the EEA, personal
information collected from you, including via the Site, will be transferred to
recipients in countries located outside the EEA (including in Singapore where
the Site is hosted) which do not provide a similar or adequate level of
protection to that provided by countries in the EEA. You hereby expressly
consent to the transfer of your personal information to recipients, as
described in this Privacy Policy, which are located outside the EEA. AdogTech
has entered into EU standard contractual clauses (“Model Contracts”) for
intra-group transfers of personal information to its affiliates. You can
request a copy of these Model Contracts by submitting your request via email to
Laura@adogtech.com.
6. Your Data Rights
If you are in the EEA, you have a right to
(subject to a limited number of exceptions): (i) request access to and rectification
or erasure of your personal information; (ii) obtain restriction of processing
or to object to processing of your personal information; and (iii) ask for a
copy of your personal information to be provided to them, or a third party, in
a digital format. You also have the right to lodge a complaint about the
processing of your personal information with your local data protection
authority in the EEA.
If you are residents of the State of
California in the United States, effective from January 1, 2020, you can
request the following information about how we have collected and used your
personal information during the past 12 months:
The categories of Personal Information we
have collected.
The categories of sources from which we
collected the Personal Information.
The business or commercial purpose for
collecting and/or selling Personal Information.
The categories of third parties with whom
we share the Personal Information.
The categories of Personal Information that
we sold or disclosed for a business purpose.
The categories of third parties to whom the
Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the
Personal Information that we have collected about you during the past 12
months.
You can ask us to delete the Personal
Information that we have collected from you.
You are entitled to exercise the rights
described above free from discrimination as prohibited by the CCPA.You may
submit requests to exercise your California privacy rights described above by
writing to us at: Laura@adogtech.com and (ii) opt out of selling of your data
by clicking on the following link: DO NOT SELL MY DATA . You can provide opt-in
consent for sale of personal information about them by writing email to us at
Laura@adogtech.com.
These rights are not absolute, and in some
instances, we may decline your request as permitted by law. We will need to
verify your identity to process your information, access, and deletion requests
and reserve the right to confirm your California residency.
7. Security of Your Personal Information
We are committed to protecting the security
of your personal information. We use a variety of security technologies and
procedures to help protect your personal information from unauthorized access,
use, or disclosure. We will only keep your personal information for as long as
necessary and in any event in relation to personal information collected by us
on the Site we will only keep this personal information for one (1) year. For
personal information collected via Google Analytics the following retention
periods apply: https://support.google.com/analytics/answer/7667196?hl=en
8. The Protection of Minors
The Site does not knowingly collect any
personal information from minors. The personal information of any minor you
provide shall be agreed by the minor's parent or guardian in advance. Minor is
defined in accordance with the laws applicable to the Privacy Policy.
9. Marketing
We may contact you periodically by e-mail
to provide information regarding our products, services and content that may be
of interest to you. If applicable law requires that we receive your consent
before we send you certain types of marketing communications, we will only send
you those types of communications after receiving your consent. If you decide
at any time that you no longer wish to receive such communications from us, you
may follow the unsubscribe instructions provided in any of the communications
or request to be opted-out of receiving such communications via email to Laura@adogtech.com.
10. Use of Cookies and Other Tracking
Technologies
AdogTech may use cookies, or other
technology (collectively “Cookies”) to collect certain information about you
when you are visiting the Site. Cookies is a small text file that is placed on
your hard disk by a Web page server. Cookies cannot be used to run programs or
deliver viruses to your computer. The purpose of Cookies is to provide a
convenience feature to save your time. By using the Site, you consent to the
use of these Cookies. If you do not accept these Cookies, you can change your
browser’s settings to delete cookies that have already been set and to not accept
new Cookies. Please however note, that, if you delete Cookies or do not accept
them, you might not be able to use all of the features we offer, you may not be
able to store your preferences, and some of our pages might not display
properly. To find out more about Cookies, including how to see what cookies
have been set and how to manage and delete them, please visit
www.allaboutcookies.org .
11. Outside Sites and Linking
The Site may contain links and pointers to
other sites on the Internet that are owned or operated by third party vendors
and other third parties (the "Outside Sites"). AdogTech is not
responsible for the availability of, or the content located on or through, any
Outside Site, including any webcasting or other form of transmission received
from any Outside Sites. You should contact the site administrator or Webmaster
for those Outside Sites if you have any concerns regarding such links or the
content located on such Outside Sites. AdogTech permits certain third party
links to the home page of its Site, provided that AdogTech is provided with
notice of such links and does not thereafter object to such linking. AdogTech
reserves the right to revoke unilaterally any consent that it may at any time
give to any linkage, including linkages to the home page. The Outside Sites are
being provided to you only as a convenience and any link or pointer contained
on this Site does not imply endorsement of the Outside Sites.
12. Copyright
All Site content, design, text, graphics,
images, logos, buttons, icons, interfaces, audio and video clips, and the
selection and arrangements thereof are the exclusive property of AdogTech, or
its respective content providers, and are protected by United States and
international copyright laws. All software used on the Site is the property of
AdogTech or its respective software suppliers, and such software is protected
by United States and international copyright laws and other applicable laws and
treaties. Users of this Site shall not transmit/post any information to this
Site that infringes the copyright or other intellectual property rights of
others.
13. Trademarks
All trademarks, service marks and trade
names used on the Site (collectively the "Marks") are solely owned by
AdogTech. The Marks may not be used in connection with any product or service
that is not a product or service of AdogTech or that is likely to cause
confusion among customers, or that in any manner disparages or discredits
AdogTech.
14. Online Conduct
Any conduct by a person that in AdogTech's
sole discretion restricts or inhibits any other person from using or enjoying
the Site, is prohibited. You agree to use the Site only for lawful purposes and
in accordance with that prohibition. You agree that you will not post on the
Site or transmit any unlawful, harmful, threatening, abusive, harassing,
defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially,
ethnically, or otherwise objectionable material of any kind, including, but not
limited to, any material that encourages conduct that would constitute a
criminal offense, give rise to civil liability or otherwise violate any
applicable local, state, national, or international law.
15. Termination of Usage
AdogTech may, without incurring any
liability to you, terminate access by you or suspend any access to all or part
of the Site, without notice, for any conduct that AdogTech, in its sole
discretion, believes is in violation of any applicable law or this Agreement,
or is harmful to the interests of another user, a third-party, a merchant, a
sponsor, a licensor, a service provider, or the Site.
Privacy Policy of AdogTech’s Advertising
Service
1. Introduction
This Privacy Policy of AdogTech’s Advertising
Service applies to information collection and use while you: (i) view ads
served by AdogTech’s Advertising Service; (ii) interact with AdogTech’s
Advertising Service; or (iii) interact with the platforms, applications,
websites or any other service provided by AdogTech’s business partners (e.g.
app publisher, advertiser) . For the purposes of European data protection laws,
AdogTech is the data controller of your personal information.
2. What Information We May Collect
When you: (i) view ads served by AdogTech’s
Advertising Service; (ii) interact with AdogTech’s Advertising Service; or
(iii) interact with services provided by AdogTech’s business partners, we
and/or our business partner may collect the following personal information from
you: Device make, device model, operating system (e.g. iOS), device type (e.g.
smartphone, tablet, etc.), device properties related to screen size and
orientation, audio volume and battery, network connection type, IP address,
Internet browser user-agent used to access the Advertising Service, identifier
for advertisers (IDFA), timestamp, iOS identifier for advertising, OS version
of device, international mobile equipment identity (IMEI), geo-location data,
information about when and for how long you use the Advertising Service or any
service provided by AdogTech’s business partners, transactional data related to
your interaction with an application, website, platform, or service provided by
AdogTech’s business partners, such as information about the actions taken in an
application like purchases or application installations; device event
information such as crashes, system activity, hardware settings, browser type,
browser language, the date and time of your request and referral URL. We also
provide Advertising Service for our advertisers and publishers through our ad
platform. We may collect the email address, account name and password, IP
address and address of individuals using our ad platform.
3. How We Use Your Information
We use your personal information to display
advertising on your device, which may include interest-based advertising
customized to individuals’ inferred interests, preferences, locations and other
features. Where required, the publisher will obtain your consent for and on our
behalf for the processing of your personal information to display advertising
on your device. You can withdraw your consent at any time. Where necessary in our legitimate interests
we use your personal information: (i) to understand and analyze your usage
trends and preferences and improve our Advertising Service; or (ii) for purpose
of anti-fraud and traffic quality monitoring in order to perform the
contractual obligations to our advertisers and publishers. We may also use your
personal information to comply with applicable laws, regulations or codes of
practice.
4. Disclosure of Your Personal Information
We may disclose your personal information
to our business partners, including advertisers, publishers, and data tracking
companies. These business partners may use your personal information to show
you advertisements, measure your ad/site interaction, and better understand the
site and app traffic usage or user behaviour in order to improve their
services. Such partners’ use of the information that we disclose to them will be
governed by their privacy policies. We may disclose your personal information
to our trusted agents and service providers so that they can perform requested
services on our behalf. For example, we may share payment information with a
third party service provider in order to assist us with processing credit card
payments. These entities are prohibited from using User’s information for any
purposes other than providing us with requested services. We may also share
aggregate or anonymous information with other third parties in accordance with
the terms of this Policy. Our affiliates may also have access to your personal
information collected through our Advertising Service for the purposes set out
in this Privacy Policy. We may share your personal information as required or
permitted by law to comply with a subpoena or similar legal process or
government request, or when we believe in good faith that disclosure is legally
required or otherwise necessary to protect our rights and property, or the
rights, property or safety of others, including to advisers, law enforcement
agencies, judicial and regulatory authorities. We may also transfer your
personal information to a third party that acquires all or part of our assets
or shares, or that succeeds us in carrying on all or a part of our business,
whether by merger, acquisition, reorganisation or otherwise.
5. International Transfers
When you are located in the EEA, personal
information collected from you, including though our Advertising Service, will
be transferred to recipients in countries located outside the EEA (including
China, US, India, Korea, Singapore, Australia, Japan, Canada, France, Ireland,
Britain, Germany, Brazil), which do not provide a similar or adequate level of
protection to that provided by countries in the EEA. Where required by law, the
publisher and/or advertiser will obtain your consent to the transfer of your
personal information to recipients, as described in this Privacy Policy, which
are located outside the EEA. You may withdraw your consent at any time.
AdogTech has entered into EU standard contractual clauses (“Model Contracts”)
for intra-group transfers of personal information to its affiliates. You can
request a copy of these Model Contracts by submitting your request via email to
Laura@adogtech.com.
6. Your Data Rights
If you are in the EEA, you have a right to
(subject to a limited number of exceptions): (i) request access to and
rectification or erasure of you personal information; (ii) obtain restriction
of processing or to object to processing of your personal information; and
(iii) ask for a copy of your personal information to be provided to them, or a
third party, in a digital format. You also have the right to lodge a complaint
about the processing of your personal information with your local data
protection authority in the EEA.
If you are residents of the State of
California in the United States, effective from January 1, 2020, you can
request the following information about how we have collected and used your
Personal Information during the past 12 months:
The categories of Personal Information we
have collected.
The categories of sources from which we
collected the Personal Information.
The business or commercial purpose for collecting
and/or selling Personal Information.
The categories of third parties with whom
we share the Personal Information.
The categories of Personal Information that
we sold or disclosed for a business purpose.
The categories of third parties to whom the
Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the
Personal Information that we have collected about you during the past 12
months.
You can ask us to delete the Personal
Information that we have collected from you.
You are entitled to exercise the rights
described above free from discrimination as prohibited by the CCPA.
You may submit requests to exercise your
California privacy rights described above by writing to us at
privacy@mintegral.com (ii) opt out of selling of your data by clicking on the
following link: DO NOT SELL MY DATA . You can provide opt-in consent for sale
of personal information about them by writing email to us at
Laura@adogtech.com.
These rights are not absolute, and in some
instances, we may decline your request as permitted by law. We will need to
verify your identity to process your information, access, and deletion requests
and reserve the right to confirm your California residency.
7. Security of Your Personal Information
The security of your information is our
utmost priority, and we take strict measures in order to protect our data from
unauthorized access, use, disclosure or destruction of data. We have
implemented physical, technical and administrative security measures for the
Advertising Services that comply with applicable laws and industry standards.
For example, we use firewalls, encryption technology and other automated
software designed to protect against fraud and identity theft; our data is only
stored in centers that provide high-level security for your information.
Physical access is strictly controlled both at the perimeter and at building
ingress points by our staff utilizing video surveillance and other electronic
means. We also protect your privacy by seeking to minimize the amount of
sensitive data and PRI that we store on our servers in the first place. We also
seek appropriate contractual protection from our partners regarding their
treatment of user data. AdogTech may retain the information relating to you
collected as necessary for internal analytical purposes, or to comply with its
legal obligations, resolve disputes and enforce agreements (e.g. settlement).
The criteria used to determine the retention periods include: (i) how long the
personal data is needed to provide the services and operate the business; (ii)
the type of personal data collected; and (iii) whether we are subject to a
legal, contractual or similar obligation to retain the data (e.g., mandatory
data retention laws, government orders to preserve data relevant to an
investigation, or data that must be retained for the purposes of litigation or
disputes).
8. Children
We ensure that we comply with the
Children's Online Privacy Protection Act (COPPA), and does not knowingly
collect personal information about users of websites or apps directed to
children under the age of thirteen (13). If a parent or guardian becomes aware
that his or her child has provided us with information without their consent,
he or she should promptly contact us and we take reasonable steps to ensure
that such information is deleted from our files.
9. Marketing
We may contact you periodically by e-mail
to provide information regarding our products, services and content that may be
of interest to you. If applicable law requires that we receive your consent
before we send you certain types of marketing communications, we will only send
you those types of communications after receiving your consent. If you decide
at any time that you no longer wish to receive such communications from us, you
may follow the unsubscribe instructions provided in any of the communications
or request to be opted-out of receiving such communications via email to Laura@adogtech.com.
Contact Us
If you have any question or comment about
this Policy, please contact AdogTech’s Data Protection Officer at
Laura@adogtech.com.
Please be sure to include your personal
name (and the full company name, if you are inquiring on behalf of such
company), address and email address in any correspondence to us so that we can
respond to your inquiry in a timely manner.
