Ad-Tech Privacy Policy.

Scope of this policy

This Policy governs data collected when users visit or interact with digital media properties (websites, applications, and internet-connected devices) that use the Adelerate advertising platform. It does not cover information we collect when you visit adelerate.com or interact with our sales and marketing activities — that is described in our Privacy Policy.

About Adelerate

Adelerate, operated by UM CARUJE DOO, connects advertisers (buyers) with publishers (sellers) of advertising inventory across websites, applications, and internet-connected devices, including mobile phones, computers, and connected/smart TVs.

Data controller and joint controllership

UM CARUJE DOO is the controller for personal data processed by the Adelerate platform, except where a publisher acts as an independent controller for data processed on its properties. In the European Economic Area, Adelerate and its clients may act as joint controllers under the GDPR, limited to the setting and collection of identifiers and user information on the digital media properties; the publisher or client is responsible for obtaining any necessary consent and providing transparency information to its users.

How we collect data

We use tracking technologies, including cookies, SDKs, and pixels, to automatically collect device information when users visit participating digital media properties — including IP addresses, cookie data, and device identifiers — and we may assign new identifiers based on the information collected. Third parties may independently collect user information for analytics and advertising services and may build advertising profiles across multiple devices or browsers to enable personalized content and ad delivery.

Information we collect

• device characteristics (device identifiers, IP address, hashed email, and probabilistic identifiers);
• browsing and interaction data (domain, visit dates and times, search terms, video data, and click data);
• non-precise location data;
• user profiles and behavioural data; and
• precise location data, where you permit it (treated as sensitive data).

Identity solutions and cookie sync

The Adelerate platform integrates with identity solutions including ID5 to enable addressability across cookieless, in-app, and mixed environments. Server-side cookie sync is used for server-auction demand. Identity processing follows the publisher’s consent-management framework.

How we use information

We process this information to:

• select advertising using limited data;
• create profiles and use them for personalized advertising;
• measure advertising and content performance;
• understand audiences through statistics;
• develop and improve our services;
• ensure security, prevent fraud, and detect errors;
• deliver advertising and content; and
• save and communicate your privacy choices.

Depending on your jurisdiction, some of this processing may constitute “targeted advertising” or a “sale” or “sharing” of personal data under applicable law.

Measurement and reporting

Aggregated impression, click, viewability, and video-event data is processed for real-time analytics on AWS TimeStream and stored for reporting.

Legal bases (EEA)

Where the GDPR applies, we rely on different legal bases depending on the purpose. We rely on consent or legitimate interest for selecting advertising using limited data, measuring advertising and content performance, and developing and improving our services. We rely on consent only for creating and using profiles for personalized advertising, personalizing content, and understanding audiences through combinations of data. We rely on legitimate interest only for security and fraud prevention, delivering advertising, and communicating your privacy choices.

How we share information

We disclose information to:

• clients (publishers and advertisers);
• Adelerate affiliates;
• vendors and service providers;
• partners;
• recipients in connection with a business transfer; and
• law enforcement and other entities, where necessary to comply with law or protect our rights.

Your choices and opt-outs

You can opt out of interest-based advertising through youronlinechoices.eu (EDAA, EU), aboutads.info (DAA), and networkadvertising.org (NAI). Where a consent-management platform built on the IAB Europe Transparency and Consent Framework is used, you can set or withdraw your preferences through it. Opt-outs are cookie- and device-based and must be exercised separately on each device and browser. Subject to applicable law, you may also request access to, deletion of, correction of, or portability of your personal data, or withdraw consent, by contacting the data controller using the details below. We do not currently respond to “Do Not Track” browser signals.

Retention

We retain user information for as long as necessary for the purposes for which it was collected or for legitimate business purposes, including compliance with legal and regulatory obligations. Device information such as IP addresses is typically stored for up to 90 days before being anonymized and aggregated into summary reports.

Security

We use industry-standard technical and organizational measures to protect user information. However, no method of transmission or storage of information can be guaranteed to be completely secure.

Self-regulatory participation

Adelerate supports the IAB Europe Transparency and Consent Framework and adheres to the self-regulatory principles of the Digital Advertising Alliance (DAA), the European Digital Advertising Alliance (EDAA), and the Network Advertising Initiative (NAI).

Children

The platform is not directed to children. We do not knowingly collect, sell, or share personal data about individuals under the age of 16 (or the applicable age under local law).

Changes to this policy

We may update this Policy to reflect changes in our practices or in legal or regulatory requirements. Material changes will be posted on our website and communicated as required by law. The “last updated” date above reflects the latest revision.

Contact

For ad-tech privacy questions, or to reach our data protection contact, use the details below.