Privacy statement

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.

Advertisers or their intermediaries (e.g. media agencies) display their advertising campaigns through Gadsme advertising solutions on the websites or apps or games of our publisher partners. Gadsme advertising technology collects and uses data to help make online advertising more relevant as well as for ad delivery and reporting purposes. All partners and suppliers of Gadsme acknowledge our privacy policy and follow its consent. Gadsme is committed to protecting and safeguard the privacy and personal data related to individual visitors of our Website as well as our prospective and/or existing publishers. Our main office is located in Paris, France, 65 rue Condorcet. Our Chamber of Commerce number is 884 197 799.

This privacy policy details Gadsme’s data practices on how we or our external, legally and independent service partners acting on behalf of Gadsme collect, use, process and share the data we may collect through our advertising services as well as the ways in which individuals may exercise control over the use of information collected by us. Your use of the Gadsme’s Services is also governed by the Terms of Use.

As used herein, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Gadsme customer or consumer or his or her household. Please note that we may update or change this privacy policy. If we make any material changes, modification will be we available on Gadsme’s Web site.

When you use our Software and/or Marketplace and/or Platform and/or Services and/or Gadsme Website, you agree that we may collect, use and disclose your Information in accordance with the terms of this Privacy Policy. This Privacy Policy is a part of our Terms of Use, and should be read in conjunction with them.

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 dpo@gadsme.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:

  • Full name and/or company name

  • Date of birth and/or company incorporation number

  • Corporate address and/or corporate domain

  • E-mail address

  • Phone number and/or other contact information

  • Payment information and bank details

  • IP address, IDFA, Google Advertising ID, UDID and other unique identifiers

  • language information, device mark and model, device connection, Os type and version

  • localization and location

  • time and date of access and ad view

  • information about the mobiles apps that a user have or currently has installed on its device

  • information about the ads a user have already been displayed

  • General and non-personal activity log Information unique to you that is automatically collected.

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:

  • Serving and optimizing Advertisements

  • Tracking performance of ads and frequency capping

  • Advertisement reporting and tracking including studies and insights

  • Billing purposes

  • Fraud detection and protection

  • Cross device experience

  • providing customer service

  • Geo-targeting

  • Interest-based advertising

  • Providing and improving our services

  • protecting the rights and property of Gadsme and complying with Law

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:

Cookie-based identification

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.

Cookie-less environments

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.

Advertising ID

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.

4. Privacy Practices of Publishers

In our Terms & Conditions, we require Gadsme’s Publishers to post a privacy policy, to obtain all required end user consents, and to comply with all applicable laws and self-regulatory guidelines, but we are not responsible for your privacy practices. To assist you in your compliance with your obligations under applicable law, our Privacy Policy contains information on the way Gadsme processes end user personal data.

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:

  • The collection of their data by Gadsme as described in this Privacy Policy, including a link to this Privacy Policy;

  • That their data will be collected by Gadsme to show ads on your applications or games, including ads which are based on behavioral targeting (for example: ads for games which are similar to those which they have installed and played before);

  • Their rights as data subjects, as described in Section “XXX”;

  • Their right to withdraw consent at any time;

  • Their right to lodge a complaint with a supervisory authority

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.

  • Programmatic Buyers: We may send part of the user profile to programmatic buyers using demand side platforms such as Google Display & Video 360, who buy our ad placements through programmatic ad auctions. Those companies are responsible as independent controllers of the data used to deliver their ads on Gadsme’s network.

  • Viewability measurement: We may transmit data to companies specialized in campaign measurement.

  • Fraud detection: We may transmit data to companies specialized in preventing delivering our ads on fraudulent traffic, such as non-human traffic.

  • Geo-location: We may transmit the IP address of the user to companies such as digital elements which provide geo-location services.

  • Analytics and Audience measurement: We transmit data to companies in order to validate the accuracy of our targeting or measure the demographic reach of our network.

  • Affiliates: We may disclose the information we collect through the Services to our affiliates or subsidiaries for the purposes described in this privacy policy; however, if we do so, their use and disclosure of your personal information will be subject to this privacy policy.

  • Hosting: We utilize third party hosting and data-center providers to store data.

  • Data sharing agreement: We process data sharing with selected brands.

Other Disclosures

We also may disclose information in the following circumstances.

  • Business Transfers: If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.

  • In Response to Legal Process: We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.

  • To Protect Us and Others: We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which Gadsme is involved.

  • Aggregate and De-Identified Information: We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

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:

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).

  • We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our products and Services, and to provide, secure, and improve our products and Services.

  • We find such processing is necessary to comply with our legal obligations.

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.

Third-Party Links

Ads within the Gadsme Ad Network may contain links to third-party websites and applications. Any access to and use of such linked websites or mobile apps is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties This privacy policy only addresses the use and disclosure of information and data by Gadsme. Publishers, advertisers and other websites that may be accessible through our Services have their own privacy policies and practices that govern the collection, use, and disclosure of your personal information when you interact with their services and use their products. We encourage you to familiarize yourself with the privacy policies provided by all third parties prior to giving them information or taking advantage of an offer or promotion.

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.

Your personal information will be retained in accordance with our data retention policy which is designed to retain data for as long as needed for us to comply with our contractual obligations, employment obligations, and other business purposes, including global legal obligations to retain data. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law.

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:

  • How to Request Access to Personal Information: You may request access to your personal information twice in a 12-month period. To do so, please, email us at dpo@gadsme.com.

  • How to Request Deletion of Personal Information: You may request that Gadsme delete the personal information it has collected and/or maintained about you. To do so, please email us at dpo@gadsme.com.

  • Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.
  • How to Opt-Out of the Sale of Personal Information: We offer an opt-out from the use of cookies and other tracking technologies in connection with our Services, which may in some cases constitute the sale of your personal information under the CCPA or other privacy laws. To opt-out of the sale of your personal information follow the browser setting instructions below. This will cause information to cease to be added to any cookies or other tracking technologies that have been set on our Services or block them entirely. It will also inhibit targeted advertising. Please note that you will need to opt out again if you visit one of our Services from a different device or browser or if you clear your cookies.

Verification

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).

Authorized Agents

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.

Anti-Discrimination Right

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 dpo@gadsme.com. 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

You are responsible for ensuring the accuracy of the Information you provide us. Inaccurate Information will affect the information you receive from us and/or other third parties and our ability to contact you as contemplated in this Privacy Policy. You hereby consent to having us and/or third parties contact you via any and all contact details included in the Information, as well as use these contact details to promote and market to you various products and services, including (but not limited to) products and services provided to us and/or by third parties. We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Site Terms and Conditions. We may transfer the Information outside your country of residence and store it in other countries; the data protection and other laws of these countries may not be as comprehensive as those in your country - in these instances we will take steps to ensure that a similar level of protection is given to the Personal Information.

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.

12. Children

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

By agreeing to the Terms and Use or by continued use of the Software and/or Marketplace and/or Platform and/or Services and/or our Website, you agree to be bound by this Privacy Policy, and to any changes that we may make to this Privacy Policy from time to time. We will notify you of any such changes to the Privacy Policy by posting the changes on the Privacy Policy. We recommend that you revisit this Privacy Policy regularly. Your continued use of the Software and/or Marketplace and/or Platform and/or Services and/or App and/or our Website in relation to any of the aforementioned, following the posting of changes to this Privacy Policy, means you accept these changes. If you feel the rights to personal data related to you had been infringed by Gadsme, please get in touch with our DPO at dpo@gadsme.com.