Aditude has acquired CPMStar, a leading monetization and SSP solution for gaming publishers and developers. Learn more!
Effective Date: March 27, 2024
1. Introduction
2. About Our Services
3. Scope
4. What Information We Collect
5. Use of Cookies and other Tracking Technologies on Our Site
6. Why We Collect Information
7. When We Disclose Information
8. Retention of Personal Information
9. Your Choices About the Information We Collect
10. Children’s Privacy
11. Visitors to the Site Outside of the United States
12. Links
13. Security
14. Your California Privacy Rights
15. Your Privacy Rights under Other US State Laws
16. Your Rights Under the General Data Protection Regulation
17. Your Rights Under the UK GDPR
18. Changes to This Privacy Notice
19. Contact Us
Welcome. You have arrived at a website provided by Aditude, Inc. (“Aditude,” “we,” “our” or “us”). Aditude is a team of adtech innovators obsessed with helping publishers. We love to help them grow and thrive. And we're very, very good at it. We’ve been in adtech since the beginning, and nobody knows ad operations like we do. From pioneering the first header bidding integration before prebid was a thing, to managing ad ops for the largest publishers on the planet, we’ve done it all. At Aditude, we take your privacy seriously. We provide this Privacy Notice (“Notice”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information. If you have questions about this Notice after you review it, feel free to contact us at privacy@aditude.io.
We provide technology that connects buyers of advertising inventory (“Advertisers”) with sellers of advertising inventory (“Publishers”). In other words, we provide Advertisers with the opportunity to display their advertisements across Publishers’ websites and applications (collectively, “Digital Media Assets”). In this Notice, we refer to Advertisers and Publishers collectively as “Clients.”
When an Advertiser serves an advertisement on a Publisher’s Digital Media Asset, the advertisement will be displayed to consumers (“Consumers”) in connection with the content that they view. For example, if a Consumer visits a video-streaming Digital Media Asset and clicks on a video to stream, then an advertisement may appear before the video is shown because the Advertiser successfully purchased the opportunity to display an advertisement before that video.
We collect certain kinds of Personal Information from Consumers, current and potential Clients, visitors to our Site (“Site Visitors”) and individuals applying for employment with us (“Employment Applicants”). For the purpose of this Notice, "Personal Information" means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. The definition of Personal Information does not include publicly available information from federal, state, or local government records, such as professional licenses and real estate or property records.
This Notice applies to our collection of Personal Information through the following channels:
We refer to all the above as our “Services.” This Notice does not apply to the collection, use and disclosure of Personal Information by our Clients through their Digital Media Assets, which is governed by their own privacy policies and practices.
We collect Personal Information in a variety of ways:
As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you.
As you interact with our Site or Services, we collect the following Personal Information via webforms or inputs/uploads on our Site, and through telephone calls, letters, emails and other communications with you.
Like many businesses, we and our service providers automatically collect and/or store certain Personal Information from Clients, Site Visitors and Employment Applicants when they visit the Site or interact with our Services.
Specifically, we collect via cookies and other tracking technologies the following “Usage Information,” which may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”):
For location information, some of our Services include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). If you use Location-Based Services, we collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.
If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.
As a part of our business model, we also collect Personal Information from Consumers when they interact with our Clients’ Digital Media Assets.
Specifically, we collect via cookies and other tracking technologies the following Usage Information, which may be stored and/or accessed from your Device:
Related to Our Site and Services: In addition, our Site includes functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Aditude from third parties. We might also provide links to make it easier to send a communication from the Site, or we may use third parties to make it easier to send emails or post to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Aditude. We do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.
Related to Digital Media Assets: As a part of our business, we collect from our Clients the following pseudonymous Personal Information about Consumers:
We use various methods and technologies on our Site to store or collect Usage Information (“Tracking Technologies”). (For information about how our Clients use Tracking Technologies on their own sites, please visit their privacy policies). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
We may use the following types of cookies:
For CPMstar-related requests: You may click here to opt out of tracking cookies.
We use the information we collect about you in a variety of ways, including the following:
We process certain Personal Information when you access or use Site or Services, including to:
We process certain information to communicate with you in relation to Client accounts, our services, our marketing, and your requests, including to:
We want to ensure that our Site and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:
We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:
To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.
We use your Personal Information to evaluate your application for employment or administer employment benefits.
We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.
We process certain Personal Information when you access one of our Clients’ Digital Media Assets, including to:
To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations related to our Site or Services as well as our Clients’ Digital Media Assets:
Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Site or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.
Aditude will retain your Personal Information only for as long as is necessary for the purposes set out in this Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
All information you provide to us is stored on our secure servers or those of our third-party data storage providers.
We utilize the following criteria to determine the length of time for which we retain Personal Information:
We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).
You can opt out of receiving marketing emails from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Notice.
You can opt-out of cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Sites’ cookie preference centers.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:
Note that if you turn cookies off, you may be unable to access certain parts or benefit from the full functionality of the Sites. To learn more about cookies and similar technologies or to opt-out of targeted advertising cookies, visit resources from the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs.
Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.
Our Site is not intended for use by children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are the parent or guardian of a child under 18 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.
All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Notice.
For your convenience, the Site and this Notice may contain links to other websites. Aditude is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Aditude endorses or has any affiliation with the links.
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk.
This section of the Notice applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.
California residents have the following rights:
California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.
We have collected the following categories of Personal Information from consumers within the last twelve (12) months. Please note that some categories might not apply to some individuals. Please see the “What Information We Collect” section above for more information.
Category of Personal Information | Recipient Categories | Sources of Personal Information | Business Purpose for Collection | |
|---|---|---|---|---|
Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name or other similar identifiers. | You Automatically Third Parties (Site Visitors, Clients and Employment Applicants only) | To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law | |
Personal information described in California Civ. Code § 1798.80(e) | Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance Notice number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | You Automatically Third Parties (Clients and Employment Applicants only) | To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law | |
Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchase history. | You Automatically (Clients only) | To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law | |
Internet or other electronic network activity information | Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. | Automatically (Site Visitors, Clients, Consumers and Employment Applicants) | To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law | |
Geolocation data | Physical location and/or movements. | You Automatically | To provide, improve and market our products and Services | |
Professional or employment-related information | Current or past job history or performance evaluations | You Third Parties (Employment Applicants only) | To provide, improve and market our products and Services To provide information you requested To verify identity To prevent fraud To comply with law | |
Inferences drawn from other Personal Information | Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | You Automatically Third Parties (Consumers only) | To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law | |
Sensitive Personal Information | Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data | You (Employment Applicants only) | To provide, improve and market our products and Services To provide information you requested To verify identity To prevent fraud To comply with law |
Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above.
We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:
Category of Personal Information | Recipient Categories | Purpose for Sale/Sharing | |
|---|---|---|---|
Identifiers | Advertising, marketing, and analytics providers | Marketing | |
Internet or other electronic network activity information | Advertising, marketing, and analytics providers | Marketing and analytics | |
Geolocation data | Physical location and/or movements. | To provide, improve and market our products and Services | |
Inferences drawn from other Personal Information | Advertising, marketing, and analytics providers | Marketing and analytics |
We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:
Category of Personal Information | Recipient Categories | Business Purpose for Disclosure | |
|---|---|---|---|
Identifiers | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services | |
Personal information described in California Civ. Code § 1798.80(e) | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services | |
Characteristics of protected classifications under California or federal law | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services | |
Commercial information | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services | |
Internet or other electronic network activity information | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services | |
Professional or employment-related information | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services | |
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) | N/A | N/A | |
Inferences drawn from other Personal Information | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services | |
Sensitive Personal Information | Service Providers | Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services |
Related to our Site: As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” If you wish to opt out of the aforementioned, you may submit a request to opt-out by emailing us at privacy@aditude.com
Related to Digital Media Assets: If you are a Consumer who has reached a Digital Media Asset of one of our Clients, please contact that Client to opt out of the sale of Personal Information and targeted advertising.
California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Currently, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you.
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes.
You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by emailing us at privacy@aditude.com.
If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
For CPMstar-related requests: Please use this link to exercise your rights to opt out click here to opt out.
Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:
To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us by email at privacy@aditude.com using the information in the Contact Us section below.
We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
Related to our Site: You may have the right to opt out of the sale of Personal Information and targeted advertising. To exercise your right, you may submit a request to opt-out by emailing us at privacy@aditude.com. If you are a Consumer of one of our Clients, please contact that Client to opt out of the sale of Personal Information and targeted advertising.
Related to Digital Media Assets: If you are a Consumer who has reached a Digital Media Asset of one of our Clients, please contact that Client to opt out of the sale of Personal Information and targeted advertising.
Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.
In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.
If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.
This section of the Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section.
Under applicable law, we are considered a data controller for data collected on our Site and in most cases are considered a processor for our Clients.
We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that are required in connection with the purposes set out in this Notice.
If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:
If you are a Consumer who has reached a Digital Media Asset of one of our Clients, please contact that Client to opt out of the sale of Personal Information and targeted advertising.
We rely on the following legal bases for processing your Personal Information:
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:
Email: privacy@aditude.io
If you are based in the United Kingdom, the following provisions also apply:
If we share your personal data within Aditude or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.
You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.
We may change this Privacy Notice at any time. We will post all changes to this Notice on this page and will indicate at the top of the page the modified Notice’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy Notice. If required by the applicable law, we will notify you of the changes.
By continuing to use the Site or Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be bound by the Privacy Notice as changed.
If you have any questions or suggestions regarding this Notice, please contact us as follows:
Aditude, Inc.
651 N. Broad St.
Suite 201
Middletown, DE 19709