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Platform Privacy Policy

Platform Privacy Policy

Last updated: 9th January, 2024

This Platform Privacy Policy (“Policy“) provides information about how adsquare GmbH (“Adsquare”, “we”, “us”) processes Personal Data within the scope of the products and services that we offer through our Platforms.

Adsquare’s processing of Personal Data is subject to applicable data protection laws such as the General Data Protection Regulation (EU) 2016/679 (“GDPR“) and applicable national data protection laws (e.g. the Federal Data Protection Act (“BDSG“).

Terms such as “Controller“, “Processor“, “Data Subject“, “Personal Data“, “Processing” (and “Process“) and “Special Categories of Personal Data” shall therefore have the meanings given in the EU General Data Protection Regulation.

If you reside in the U.S., please visit our US Privacy Supplement section.

1. What we do

Adsquare offers a digital advertising technology platform that facilitates the creation and execution of targeting, measuring, and analysing digital and location-based advertising campaigns. It provides a transparent and neutral data exchange platform that brings advertisers and data providers together in a fair, secure, and privacy-friendly way.

This helps companies to make their marketing campaigns more relevant, reducing the number of ads you see that aren’t beneficial or of interest to you and validating their effectiveness. An opt-out from targeting would not reduce the number of ads, it just makes the ads you receive less relevant.

The platform has been built mobile-first in Germany with user privacy at the core of its design from day one. Therefore, it complies with the European General Data Protection Regulation and other local privacy laws such as the CCPA.

In a nutshell:

  • Adsquare does not collect the Personal Data that is processed for  providing its products and services through our platforms. Adsquare’s platform processes the Personal Data provided by third-party data partners which have chosen to cooperate with Adsquare.
  • Data partners provide Adsquare a licence to use their data as a Data Controller. This means that Adsquare decides on the purposes and means for processing the Personal Data.
  • The platform allows advertisers to use and manage data in order to improve their effectiveness and analyse their online and offline advertising campaigns. This helps them to provide you with more relevant advertising, e.g. based on your interests and affinities.
  • This data uses pseudonymous advertising identifiers associated with your mobile device rather than names, e-mail addresses or phone numbers.
  • For some products such as Post-Campaign Footfall Measurement, Audience Insights and some Audience Targeting cases, Adsquare also processes Personal Data on the behalf of a client as a Data Processor. In those cases, the client is the Controller of the Personal Data.

For information about Personal Data collected on our website please visit our Website Privacy Policy.

2. Controller Information

For this Policy, please note that Adsquare is the Controller of all Personal Data provided by third-party data partners. Personal Data is processed in the context of providing Adsquare’s products and services such as but not limited to Audience Targeting, Real-Time Footfall Measurement, OOH Planner, Place Visits or Lookalike Modelling through our platforms.

The legal entity in control of the Personal Data is adsquare GmbH, a company incorporated under the laws of Germany (registration number HRB 171195 B (Amtsgericht Charlottenburg) whose principal place of business is at Saarbrücker Str. 36, 10405 Berlin, Germany.

If you have any questions or concerns about the Controller’s use of Personal Data or if you have questions about privacy at Adsquare, please contact us or our Data Protection Officer using the contact details provided under the “Send us your privacy request” heading below or via our email: privacy@adsquare.com.

For some of our clients Adsquare may act as a Processor of their data. 

Adsquare is a registered Vendor of the IAB Europe Transparency and Consent Framework (TCF), our Vendor ID is 66. 

3. Sources of Personal Data

  • Clients’ and Partners’ employees that provide their Personal Data to Adsquare to create their platform account as part of a contractual relationship.
  • Partners that collect and provide Adsquare with data, including Personal Data, to be used in our platforms. 
  • Clients that upload their data in our platform for their use.
  • Third party software in our platforms as explained in section 4 below. 
  •  

4. What Personal Data do we collect and for which purposes?

A: Information collected from clients using the Adsquare Platforms

Who collects the Data Personal Data collected Why are we using it?
Adsquare Platform Name, E-mail address, company name, position, phone number, and country of the clients' and partners' employees that have access to the Platform This Data is used to create our clients’ and partners’ accounts on the Platforms, to maintain their accounts, to let our clients and partners interact with other Platform members and to use the products and services offered through the Platforms.
Adsquare Platform IP address of the client that uploads data in the Platform This Data is collected only one time to create the electronic signature for the Data Processing Agreement between the company using the Platform and Adsquare.
Google Analytics (Processor) IP address of the client that access the Platform
  • Measure product performance
  • Measure product retention
  • Measure product effectiveness
  • Measure product value
  • Measure and analyse user behaviour
  • Reports on
    • overview of products
    • demographics, geo-location, device type etc.
    • product traffic
    • behaviour
    • conversion
Intercom (Processor)
  • IP address
  • Unique device identifiers
  • How long you spent on a page or screen
  • How you interact with our emails
  • Navigation paths between pages or screens
  • Date and time
  • Customer communications platform
  • Customer management
  • User information database
  • User tagging
  • User grouping
  • User personalisation
    • User reaching
    • User messaging
  • User reminder
Hotjar Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices.
This includes:
  • Name, email
  • Device's IP address (processed during your session and stored in a de-identified form)
  • Device screen size, device type (unique device identifiers),
  • Browser information
  • Geographic location (country only),
  • Preferred language used to display our website
 We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback.

Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

B: Information collected from users by third parties that we process through the Adsquare Platforms

Permitted purpose Types of personal data Description Legal basis for data collected in the EEA
TCF 2. Use limited data to select advertising
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Advertising presented to you on this service can be based on limited data, such as the website or app you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you) ("targeting").
    • Combination data obtained offline with data available in the moment, about the user, to select an ad ("local contextual targeting")
    • Using precise geolocation data to select and deliver an ad in the moment, without storing it ("precise local contextual targeting")
    		 Consent
    TFC 3. Create profiles for personalised advertising
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Information about your activity on this service (such as forms you submit, content you look at) can be stored and combined with other information about you (for example, information from your previous activity on this service and other websites or apps) or similar users. This is then used to build or improve:
    • A profile about you (that might include possible interests and personal aspects)
    • Your profile can be used (also later) to present advertising that appears more relevant based on your possible interests by this and other entities
    • Associate data obtained offline with an online user to create or edit a user profile for use in advertising, provided that a legal basis was established offline at the point of data collection ("offline data onboarding")
    • Collecting data for deterministic cross-device mapping (e.g. if a user logs into an account on one device and then on another)
    • Select a personalised ad, based on a personalised ads profile, by processing precise geolocation previously stored or made available in the moment ("place visit creation")
    		Consent
    TCF 4. Use profiles to select personalised advertising
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Advertising presented to you on this service can be based on your advertising profiles, which can reflect your activity on this service or other websites or apps (like the forms you submit, content you look at), possible interests and personal aspects.
    • Select a personalised ad, based on a personalised ads profile, by matching and combining data obtained offline with the data stored in an online profile ("offline data targeting")
    • Select a personalised ad, based on a personalised ads profile, by linking different devices ("cross-device targeting")
    • Select an ad based on precise geolocation previously stored ("place visit targeting")
      • These profiles influence the decision as to which ads/content are displayed to the consumer. However, this decision is not solely based on these profiles.
    		Consent
    TCF 5. Create profiles to personalise content
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Information about your activity on this service (for instance, forms you submit, non-advertising content you look at) can be stored and combined with other information about you (such as your previous activity on this service or other websites or apps) or similar users. This is then used to:
    • Build or improve a profile about you (which might for example include possible interests and personal aspects)
    • Your profile can be used (also later) to present content that appears more relevant based on your possible interests, such as by adapting the order in which content is shown to you, so that it is even easier for you to find content that matches your interests
    • Associate offline data with an online user to create or edit a user profile for use in content personalisation provided that a legal basis was established offline at the point of data collection ("offline data onboarding")
    • Collecting data for deterministic cross-device mapping (e.g. if a user logs into an account on one device and then on another) ("cross-device segmentation")
    • Store precise geolocation data in a profile for use in content personalisation ("place visit creation")
    		 Consent
    TCF 6.Use profiles to select personalised content
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Content presented to you on this service can be based on your content personalisation profiles, which can reflect your activity on this or other services (for instance, the forms you submit, content you look at), possible interests and personal aspects, such as by adapting the order in which content is shown to you, so that it is even easier for you to find (non-advertising) content that matches your interests. Personalised content can be shown to consumers based on a profile about them. This includes:
    • Select personalised content, based on a personalised content profile, by matching and combining data obtained offline with the data stored in an online profile ("offline data targeting")
    • Select personalised content, based on a personalised content profile, by linking different devices ("cross-device targeting")
    • Select personalised content, based on a content profile, by processing precise geolocation previously stored or made available in the moment ("place visit targeting")
      • These profiles influence the decision as to which ads/content are displayed to the consumer. However, this decision is not solely based on these profiles.
    		Consent
    TCF 7. Measure advertising performance
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns. This includes:
    • Measuring ad performance by matching and combining data obtained offline with the data obtained online ("offline data measurement")
    • Measuring ad performance by linking different devices ("cross-device measurement")
    • Measuring ad performance by processing precise geolocation previously stored or made available in the moment ("footfall measurement")
    		 Consent
    TCF 8. Measure content performance
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Information regarding which content is presented to you and how you interact with it can be used to determine whether the (non-advertising) content e.g. reached its intended audience and matched your interests. For instance, whether you read an article, watch a video, listen to a podcast or look at a product description, how long you spent on this service and the web pages you visit etc. This is very helpful to understand the relevance of (non-advertising) content that is shown to you. This includes:
    • The performance and effectiveness of content that consumers see or interact with can be measured.
    • Measuring content performance by matching and combining data obtained offline with the data obtained online ("offline data measurement")
    • Measuring content performance by linking different devices ("cross-device measurement")
    • Measuring content performance by processing precise geolocation previously stored or made available in the moment ("footfall measurement")
    		 Consent
    TCF 9. Understand audiences through statistics or combinations of data from different sources
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Reports can be generated based on the combination of data sets (like user profiles, statistics, market research, analytics data) regarding your interactions and those of other users with advertising or (non-advertising) content to identify common characteristics (for instance, to determine which target audiences are more receptive to an ad campaign or to certain contents). This includes:
    • Market research can be used to learn more about the audiences who visit sites, apps or locations and view ads or are exposed to offline ads such as OOH posters.
    • Matching offline obtained data (panel data) to online obtained data ("offline data insights")
    • Apply market research to generate audience insights by linking different devices ("cross-device insights")
    • Use precise geolocation data to apply market research data in order to generate audience and location insights ("footfall insights", "OOH planning")
    		Consent
    TCF 10. Develop and improve services
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Information about your activity on this service, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This includes:
    • Consumers' data can be used to improve existing systems and software, and to develop new products.
    • Developing and improving products by matching and combining data obtained offline with the data obtained online
    • Developing and improving products by linking different devices
    • Developing and improving products by processing precise geolocation previously stored or made available in the moment
      • This specific purpose does not include the development or improvement of user profiles and identifiers.
    		Consent
    TCF 11. Use limited data to select content
  • Mobile Advertising ID
  • Location data (lat, long)
  • Date and time of accessing client's and/or partner's digital properties or location
  • Cookie information
  • Audience segments
    		•  Content presented to you on this service can be based on limited data, such as the website or app you are using, your non-precise location, your device type, or which content you are (or have been) interacting with (for example, to limit the number of times a video or an article is presented to you). Consent

    (For more information on the “Types of Data” and purposes, please refer to our section Understanding Privacy and Data Protection).

    5. Who do we share your information with?

    We disclose your information to the following categories of recipients:

    • To our affiliate and third-party services providers who provide data processing services to us and support us in providing our products and services, or who otherwise process Personal Data for purposes that are described in this Privacy Policy or notified to you when we collect your personal information,
    • To our Clients and Partners including digital marketers, advertising agencies, publishers, demand side platforms, data management platforms or supply-side platforms which are listed in our Partner List (available link: www.adsquare.com/partner-list),
    • To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person,
    • To a potential buyer (and its agents and advisors) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.

    6. Your rights as a Data Subject

    As a company located in the EU, we guarantee your GDPR rights to:

    •   Access

    You can obtain information about the Personal Data that we have about you.

    •   Rectification

    You can ask us to correct the Personal Data that we have about you that is incorrect, inaccurate, or incomplete.

    •   Data Portability

    You can request your information in a format that is machine-readable.

    •   Object Processing

    You can object the processing of your personal data for marketing purposes.

    •   Restrict Processing

    You can request the restriction of the processing activities.

    •   Erasure

    You can request your data to be erased.

    If you wish to exercise any of these rights, you can do so at any time by using the contact details provided under the “Send us your privacy request” heading below or write to our email: privacy@adsquare.com.

    If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

    To opt-out from our marketing communications please refer to our Website Privacy Policy below or write to our email: privacy@adsquare.com.

    You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. (contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here).

    If you are a reside in the U.S., please refer to our US Privacy Supplement.

    7. How long do we keep your information?

    Personal Data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Policy or as otherwise required by applicable law (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).  

    We do not keep any Personal Data longer than 13 months. In fact, most products and services have automated deletion processes that delete your data much earlier, e.g., after 92 or in some cases 185 days. Only for some statistical analyses we store some data up to 13 months. In other words, any data that can be related to your internet devices are deleted after a maximum of 13 months.

    8. International Data Transfer

    Our servers are in the European Union (the Netherlands, France, and Germany). However, Personal Data may be transferred to and processed in other countries as some third parties we share your information with may operate outside the EEA (e.g. United States of America). This means that when we transfer your Personal Data to these third parties, your information will be processed outside the EEA. Where applicable laws require us to utilise a data transfer mechanism, we rely on adequacy decisions as adopted by the European Commission, standard contractual clauses issued by the European Commission or pursuant to established derogations for specific situations. You may obtain a redacted copy (from which commercial information and information that is not relevant has been removed) of such EU Standard Contractual Clauses by using the contact details provided under the “Send us your privacy request” heading below.

    9. Legal basis for processing (EEA Data Subjects only)

    If you are a Data Subject from the European Economic Area (EEA), our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. 

    We collect and process information from you only:

    • where we have your consent (Art. 6 para 1 lit. a) GDPR),
    • where we need the information to provide our contractual obligation to you (Art. 6 para 1 lit. b) GDPR) or
    • where we have a legitimate interest to do so.

    The processing activities regarding the categories of data and purposes described in 4.B and non-necessary cookies in 4.A are always based on consent.

    If you wish to learn more about specific legal ground(s) we rely on to process your information for any particular purpose (including any legitimate interests we have to process information), then please contact us using the contact details provided under the “Send us your privacy request” heading below.

    10. Opt-Out Options

    Via Device Settings

    Data is only processed in order to show you the most relevant advertising content and to provide statistical analytics products and services. If you’re opposed to this, always read the terms and conditions and privacy notices when installing new apps. Many websites and mobile applications provide opt-out options, and you have the option to limit ad tracking on your smartphone. 

    If you wish that your location be private, you can turn the geo-location feature off within the location settings of your device. In addition to this, you can disable ad tracking on your device so that Adsquare will no longer include device information in its audience segments or analytics products and services.

    The following instructions explain how to turn off ad tracking for Apple and Android devices:

    iOS:

    • Choose Settings > Privacy & Security > Tracking
    • Turn off “Allow Apps to Request to Track” or make your choice per app below

    Android:

    • Choose Settings > Google > Ads
    • Check Opt out of Ads Personalisation
    • Toggle it off, then tap on “Reset advertising ID”

     

    Via Advertising ID

    To specifically opt-out from our services without changing your device settings, you can use the form provided under the “Send us your privacy request” heading below to submit your Advertising ID to our platform. To find out your Advertising ID, use the following instructions:

    • iOS users have to download an app (e.g. The Identifiers) and copy the “Advertising Identifier”
    • Android users choose Google Settings > Ads and copy the “advertising ID”

    Send us your privacy request

    We encourage you to explore our Privacy Centre to fully understand how Adsquare manages your Personal Data and to reach out with any questions you have using the below contact form or by email to privacy@adsquare.com. If you reside in the U.S., please refer to our US Privacy Supplement.

      (alphanumeric scheme: 00000000-0000-0000-0000-000000000000)

      * Required field. You can change your mind at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at marketing@adsquare.com. We process your information in accordance with our Privacy Policy which you can review here.Adsquare does not process your name, email address, phone number, or home address, unless you have explicitly subscribed to our newsletter and marketing communications. We want to assure you that this Personal Data is not used in any Adsquare products and it is not necessary to send any additional personal data to unsubscribe. We respect your privacy and only use the information you have willingly provided.If your request is related to the solutions that Adsquare offers or for OPT-OUT / Deletion request we only require your Mobile Advertisement ID and an email address to communicate with you. Please do not share additional information such as phone number, home addressee, personal ID information, etc, as this is not necessary. In case of an Access Request, we will contact you if any other information is required.For information on how to find your Mobile Advertising ID please follow the instructions here.