Services Privacy Policy

This Privacy Policy describes how Bertian Ventures, LLC (“AdGent.io,” “we” or “us”) collects, receives, uses, retains, processes, discloses, transfers, and secures Personal Information through our suite of advertising services (“Advertising Services”). It also describes your choices regarding use, access, deletion, and correction of your Personal Information. Our clients, including advertisers or publishers, are referred to in this Policy as “Advertising Customers.” All references to “you,” “your” or “user” apply to consumers whose Personal Information we collect for our Advertising Services. For information about our data practices on our website located at https://www.adgent.io, or our partner websites, please review our Website Privacy Policy.

“Personal Information” in this Privacy Policy is information about you that is personally identifying or could reasonably be used to identify you, such as your name, email address, or telephone number. The definition of Personal Information depends on the laws that apply in your location and may include other types of information as well, such as location data (including precise geo-location data), your Internet Protocol (IP) address, your mobile advertising identifier, or another unique identifier. This Privacy Policy covers information we collect online only, unless local law requires otherwise.

1. CHANGES TO THIS POLICY

This Privacy Policy may change from time to time, so please check back periodically for any changes. If we make any material changes, we will notify you by means of a notice on our website prior to the change becoming effective.

2. INFORMATION WE COLLECT

AdGent.io provides its online Advertising Services to Advertising Customers through site retargeting, search retargeting, contextual retargeting, Facebook API, and location-based services, including geolocation of Internet users (“GeoFencing”). These services are generally provided through third-party websites owned and/or operated by our Advertising Customers who publish their own content on the Internet.

We may receive Personal Information such as physical addresses from our Advertising Customers, which we de-identify and use for GeoFencing and to provide analytical reports to our Advertising Customers. We may also obtain information from third-party data providers, such as physical addresses and information about consumer characteristics such as demographics and predicted interests.

Through our Advertising Services, we collect information about users’ online activities over time and across non-affiliated websites, mobile applications, or online services, as applicable, and across multiple devices including connected TVs. We collect information about your device and your visit(s) to websites, apps, and online services, such as browser type and version, Internet service provider (ISP), mobile operating system, referring/exit pages, operating system, date/time stamp, responses by a web visitor to an advertisement delivered by us or a third party, and/or clickstream data.

We also collect information that identifies your devices, which may be considered Personal Information. This information can include, for example, IP addresses, mobile advertising identifiers, and cookie identifiers. AdGent.io collects Precise Location Data (as defined by the NAI) for your device when, for example, a user makes such information available through a third-party mobile application or webpage on a particular device. AdGent.io may receive this Precise Location Data from third-party partners. AdGent.io also engages in cross-device linking.

We may combine all of the information that we collect to provide our Advertising Services.

3. HOW WE COLLECT AND USE INFORMATION

We use cookies, JavaScript, and similar technologies to provide our Advertising Services. Among these technologies, we employ a software technology called clear gifs (or web beacons), that help us better manage the advertising content on our network of third-party sites. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online activities of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. In compliance with the Network Advertising Initiative (NAI) Code of Conduct, we do not tie the device-identifying information gathered by clear gifs to personally identifiable information except as permitted by the NAI Code.

In performing our Advertising Services, we collect information in multiple ways, including:

• On our own websites
• On the websites of publishers or Advertising Customers
• When we serve online advertisements
• From third-party providers

The collection of this data about your online activities across non-affiliated properties and linked devices allows us and our Advertising Customers to better target advertising to user interests. This process is called interest-based advertising. The Advertising Services include various analytics and measurement services as well. The data also allows us to improve our services, for example, improving the effectiveness of the advertisements delivered to users and limiting the number of times a person sees a given advertisement.

4. INFORMATION SHARING AND DISCLOSURE

We may share the information we collect with other parties for our business reasons, including the following:

• We share your Personal Information with our affiliates and third-party vendors who provide services on our behalf.
• We can disclose Personal Information to provide our Advertising Services, including disclosures to our Advertising Customers to enable them to serve interest-based advertisements to user devices based on the user’s browsing history and online activities.
• AdGent.io may also disclose any information if required to do so by law or in the good faith belief that such action is necessary to: (1) comply with legal process served on AdGent.io, (2) protect and defend the rights or property of AdGent.io, (3) protect the personal safety of users of AdGent.io, its Advertising Services, or other services, (4) provide updates and services that may be of interest to the user, or (5) prevent online fraud or other cyber threats, for example through an online threat exchange, or to report, detect and/or prevent security events.
• AdGent.io is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• AdGent.io may disclose Personal Information with notice or with your consent, where permitted by law.

5. SALE OF ASSETS

In the event that AdGent.io is involved in a potential or actual merger, acquisition, or sale of all or a portion of its assets, including in bankruptcy, we reserve the right to include, disclose and transfer any or all stored Personal Information and other data among the assets transferred to the acquiring company. If this occurs, you will be notified via email and/or a prominent notice on our Site of any change in ownership or material changes in uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

6. YOUR CHOICES

Opting Out of AdGent.io Targeted Advertising on Your Browser

AdGent.io engages in interest-based advertising activities, including cross-device linking, as described above. If you would like to stop receiving interest-based advertising from AdGent.io on your browser, click here. By doing so, AdGent.io will replace your unique cookie with an “opt-out” flag that will prevent us from serving you interest-based advertising. We will still collect and store information through such cookies for other purposes such as metrics and analytics, but the ads you see will not be tailored to you. You will need to make this opt-out choice on each browser or device that you use. In some cases, such as when you buy a new device or delete cookies from your browser, you may need to set the AdGent.io opt-out cookie again.

AdGent.io is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. Additional information on the NAI and its code can be viewed at http://www.networkadvertising.org/code-enforcement/code.

AdGent.io also licenses the AdChoices icon from the Digital Advertising Alliance (“DAA”) at http://digitaladvertisingalliance.org/ and the DAAC at http://youradchoices.ca to provide users with notice when they are being behaviorally targeted and to offer an opt-out option.

To opt-out of interest-based advertising by other companies, visit:

• Digital Advertising Alliance (DAA)’s self-regulatory opt-out page at http://optout.aboutads.info/ and the mobile application-based “AppChoices” download page at https://youradchoices.com/appchoices
• European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page at http://youronlinechoices.eu
• Network Advertising Initiative (NAI)’s self-regulatory opt-out page at http://optout.networkadvertising.org/

Do Not Track

We currently honor Do Not Track signals transmitted by browsers by treating this signal as an opt-out of interest-based advertising.

Opting Out from AdGent.io’s Location-Based Advertising

You may opt out of our collection, use, and transfer of precise location data for location-based advertising purposes by using the location services controls in your mobile device’s settings.

7. ACCESSING YOUR INFORMATION

You may request to access your Personal Information that we hold, as well as to correct, amend, or delete information when it is inaccurate or has been processed in violation of applicable law. To make such requests, please contact us at contact@adgent.io. We will respond to these requests in accordance with the laws that apply to you and within a reasonable timeframe.

8. INTERNATIONAL OR CROSS-BORDER TRANSFER OF YOUR PERSONAL INFORMATION

By providing Personal Information and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information outside your country. The Personal Information of users located outside the U.S. may be transferred to the U.S., where our servers are located. By accessing the Site, using Advertising Services, or providing Personal Information, you agree to such transfer and disclosure.

9. EU DATA SUBJECTS: PROCESSING OF PERSONAL INFORMATION

We process Personal Information with your consent. EU data subjects may have rights to access, portability, revoke consent, correct, delete, or object to the processing of Personal Information. You can email requests to contact@adgent.io. We will respond to your request in a reasonable timeframe and in accordance with the applicable law.

10. CROSS-BORDER TRANSFERS FROM EUROPE

AdGent.io complies with international data privacy frameworks and processes data in compliance with applicable regulations.

11. U.S. PRIVACY RIGHTS

U.S. residents may have certain rights under various state laws with respect to Personal Information processed by AdGent.io. These rights may include access to, correction of, and deletion of Personal Information, depending on your state of residence.

12. DATA RETENTION

We retain the information we collect through our Advertising Services for a minimum of 30 days, or longer if needed for auditing purposes. We do not retain any data collected for interest-based advertising longer than 24 months in an identifiable form, except as required by law.

We retain other Personal Information in compliance with applicable laws and as reasonably necessary for our processing purposes set out in this Privacy Policy.

13. SECURITY

AdGent.io uses commercially reasonable physical, managerial, and technical safeguards designed to preserve the integrity and security of your personal information and to protect it against loss or unauthorized use or disclosure.

14. CONTACT US

If you have inquiries or complaints regarding this Privacy Policy, please contact AdGent.io at:

Email: contact@adgent.io