Last update: July, 12th 2020
Gadsme takes your privacy very seriously, and will process and use your information carefully. We are also very transparent on this issue. You should always know what information we collect and what we do with that information.
1. What is Gadsme?
Gadsme together with its affiliates (“Gadsme” from here on out, or simply “we”, “us”, etc.) offers an advertising marketplace that proposes innovative advertising solutions to publishers -including game publishers- and advertisers all over Europe, the United States, Latin America and Asia. Publishers use Gasdme’s advertising solutions to monetize their ad spaces either directly or through Gadsme advertising demand including other advertising buyer partners.
Gadsme has appointed a Data Protection Officer (DPO) to ensure compliance with the requirements. He has direct and immediate connections with the top level management of Gadsme and remains in an independent position within the corporate structure of Gadsme. Visitors of the Website of Gadsme as well as our prospective and / or existing clients as well as our prespective and/or existing publishers can get in touch with our DPO by electronic mail service to email@example.com.
2. What information does Gadsme collect
Gadsme (or our external partners on our behalf) may collect Information about you where such Information is sent to us through your computer, mobile phone or other access device, including but not limited to: Personal identifying Information such as:
Information also includes, but is not limited to App data such as app name, logo, app store URL, app store category, app bundle ID, app cross apps tag, blocked content categories, COPPA flag, etc.
Gadsme do not collect or process information related to sensitive targeting categories as defined by the European Interactive Digital Advertising Alliance (EDAA) in the European Economic Area (EEA) and under other applicable law (e.g. religion, political opinion, health).
3. Why do we collect that Information. Data Use
Gadsme use the Information we collect to provide and improve the Gadsme Services and/or Marketplace and/or Platform and/or software and/or our Website, including but not limited, for:
We may use various tracking technologies to collect this information, such as pixel tags and pixel impression trackers from third party services and tracking technologies. We may also receive a list of unique identifiers directly from your devices, from Publishers and/or Advertisers, which we may use to determine to what end users to display (or not display) certain ads.
Separately, we may also collect email, contact, payment and related information from publishers and advertisers
In order to deliver personalized ads as well as non-personalized ads, Gadsme uses the following methods to identify users depending on the device they use, whether they access our Services on web or mobile or game or app, and operating system:
Gadsme drops a cookie on the user web and/or mobile browser. Cookies are alphanumeric identifiers that are created on your device through your web browser for record-keeping purposes. Cookies are used to identify a user and store a randomly generated identifier to identify his or her browser across visits.
For browsers setup to not allow cookies to be dropped, Gadsme uses an identification methodology based on IP address, browser, and device characteristics. This method allows Gadsme to identify a user in order to provide the same level of services, such as reporting and targeting information to users, segmenting users, and capping the number of times the same ad is shown to the same user.
Gadsme uses its software development kit (“SDK”) technology to identify your advertising ID for mobile applications. For Google Android operating system, we use the Google Advertising ID and for Apple iOS the IDFA.
You can opt-out of the use of these technologies as described in Section XXX.
In particular, information given to the end users who are based in the EU at the time their consent is asked, should include the following:
5. Data Disclosure
Data shared with Third Parties
In order to provide the Services, we need to share data (including personal information) with third party vendors, service providers, contractors or agents who perform functions on our behalf, including the ones listed below. Our service providers are authorized to use the information we provide only as necessary to provide these services to us.
We also may disclose information in the following circumstances.
Sale of Personal Information
Gadsme uses data for its business to serve clients and combines such data with other information to help enhance its products and services. Such use may be considered a “sale” under the California Consumer Privacy Act (the “CCPA”). As Gadsme uses and combines data it receives with other information to help enhance its products and services, Gadsme considers itself a third party for CCPA purposes. Advertisers (and their intermediaries) and publishers that work with Gadsme should include a “Do Not Sell” link on their website(s) to comply with the CCPA as interpreted by the California Attorney General.
Additional Disclosures for individuals in Europe
If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
When we process your personal data, we will do so, e.g., in the following situations:
Data Subject Requests
You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.
6. Data Retention and security
We retain the data linked to a user up to 12 months from the date of collection.
We may also store aggregated and non-personal data for a longer period than 12 months for financial and statistical reasons.
For security reasons, user’s IP address is stored in a private security log for a period of 4 months.
Gadsme cookie is kept up to 365 days after the last user interaction with our services.
Gadsme uses generally accepted industry security standards to protect data.
We have implemented reasonable security measures to protect the information we collect from unauthorized access, exfiltration, theft, loss, misuse, disclosure, alteration, or destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
7. Transfer of information to the U.S. and other countries
Gadsme is based in Paris and we process and store information throughout the United States, Europe, Latin America, and Asia. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.
8. Choices for access, deletion, opt out of sale or opt out from Gadsme Personalized advertising and right to non-discrimination for California
If you are a California resident, you have the right to know what personal information we collect, disclose, and “sell” about you (as that term is used in the CCPA). Additionally, you have the right to access, delete and opt-out from the “sale” of your personal information.
To exercise these rights, please follow the instructions below:
Please note, we will take steps to verify your identity before fulfilling any consumer request. If you maintain an account with us, we will verify your identity through existing authentication practices for the account (e.g., login and password). If you are not a registered member, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., browser and device ID).
You can use an authorized agent to make such requests on your behalf. But we may require the agent to provide a written permission and verify his/her identity or demonstrate that he or she has power of attorney.
You have the right to be free from discrimination in product quality, goods or services if you choose to exercise your privacy rights under the CCPA.
Do Not Track Signals
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we stop running targeted advertising when we receive a “do not track” signal. For information about Do Not Track, visit www.allaboutdnt.org.
If you do not want us to show you personalized ads (based on your inferred interests) please follow the below instructions:
To opt-out from your web browser in any devices:
If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location; they just may not be relevant to your interests.
The opt-out mechanism will only opt you out of personalized advertising delivered by Gadsme in this browser or in mobile applications on this device (e.g., phones, tablets). It will not opt you out on other devices or in other browsers you use. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Opt-out information is stored in a cookie for 5 years. If you delete your cookies, this information will also be deleted, and you will need to renew your opt-out choices.
For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.youronlinechoices.com, www.aboutads.info/choices, and other similar sites.
To opt-out from an in an app or a game environment:
If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location, they just may not be relevant to your interests.
If you want to disable Gadsme personalized ads, please refer to your operating system settings.
Mobile device system software are providing mechanisms that allow users to opt-out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt-out using these mechanisms, consult your device settings (e.g. “Opt-out of Interest-Based Ads” on Android devices and “Limit Ad Tracking” on iOS devices). Please note that this is a device setting which will disable personalized ads from all providers, and not just for Gadsme. If your device’s advertising identifier is reset, you will need to renew your opt-out choice for that device.
Your California Privacy Rights
Under the California law, California residents may opt-out of our disclosure of your personal information to third parties for marketing purposes. You can choose to opt-out of the sharing of your personal information with third parties for marketing purposes at any time by emailing us at firstname.lastname@example.org. This would mean that you wouldn’t receive any direct offers or marketing information from any services subscribed to via Gadsme’s services.
9. How does Gadsme protect your personal information?
Gadsme will take appropriate technical and organizational measures to protect your (personal) data against loss or any form of unlawful processing.
10. Transfer to countries outside or inside the EU
For technical and operational reasons, it can still be necessary for your (personal) data to be transmitted to (the servers of) Gadsme’s affiliates in the United States or other countries outside Europe, where privacy laws may not offer the same protection as in the European Union. You agree that, should the situation occur, your (personal) data may be transferred to the United States or other countries outside Europe. For those of you located in the United States, you agree that your (personal) data may be transferred to countries inside Europe.
11. Additional Terms
We are not responsible for events beyond our direct control. We cannot guarantee nor do we represent that there will be error-free performance regarding the privacy of the Information, and we will not be liable for any direct, indirect, incidental, consequential or punitive damages relating to the use or release of the Information.
Gadsme does not knowingly collect personal information from children under thirteen (13). If we become aware that a child under thirteen (13) has provided us with personal information, we take steps to remove that information and terminate the child’s account.
If a child under the age of thirteen (13) tries to register with us, we ask the child to have a parent or guardian to be present and provide parental permission for use. Still, we always reserve the right to delete an account associated with a child under the age of thirteen (13) even if parental consent is provided. We do not knowingly contact children under the age of thirteen (13) without a parent’s permission.
13. Acceptance and modification of this policy