US Privacy Supplement
Last updated and effective: 1st January 2024
This Privacy Supplement applies to consumers in:
- California as defined in the California Consumer Privacy Act (“CCPA”)
- Virginia as defined in the Virginia Consumer Data Protection Act
- Colorado as defined in the Colorado Privacy Act (“CPA”)
- Connecticut as defined in the Connecticut Data Privacy Act (“CDPA”)
- Utah as defined in the Utah Consumer Privacy Act (“UCPA”)
and supplements Adsquare’s Platforms Privacy Policy
1. Definitions
You can find the definitions of the legal and technical words used in Adsquare’s Privacy Policies in the section ‘Understanding Privacy’. To facilitate reading this Supplement, below you will find the definitions that are relevant in the specific context of the U.S. states listed above.
Personal Information: In Adsquare’s Privacy Policies you will find the term “Personal Data” to refer to Personal Information meaning any information that allows to identify directly or indirectly a Consumer.
Data Subject or Consumer: it is the natural person resident in one of the States listed above and that is identifiable as a subject in the Personal Information.
Consent: At Adsquare, consent means any freely given, specific, informed, and unambiguous indication of the Consumer’s wishes by which the Consumer, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Information relating to the Consumer.
Sensitive Personal Information: In the context of this Supplement, Sensitive Personal Information refers to the following categories of Personal Information:
- Data that reveals your racial or ethnic origin, immigration status or citizenship, political opinions, religious or philosophical beliefs
- Data that reveals if you are part of a trade union, professional or trade association
- Data concerning your health
- Data about your sex life or sexual orientation
- Data regarding your criminal convictions or records
- Genetic or biometric data to identify you
- Your identification issued by a governmental body (ID, driver’s licence, social security number, passport number, tax ID, etc)
- Account login information, financial accounts, debit card and credit card numbers in conjunction with security codes
- Content of mail and text messages
- Data concerning if you have been the victim of a crime
- Data from a known child
- Precise geolocation data from a device and that is used or intended to be used to locate a Consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,750 to 1,850 feet depending on the applicable law.
Sensitive Locations: Refers in general to places that might be linked to Sensitive Personal Information for example medical facilities, religious places, educational institutions for children, labour union offices, locations of public gatherings related to the exercise of the right to assembly, locations of organisations that provide services to minorities, women, refugees and other social group that can be the subject of discrimination.
Please find below a table to facilitate your understanding of the categories of Personal Data that we collect in relation to the CCPA classification.
2. Sources of personal information
For information about the sources of Personal Information please refer to section 3 “Sources of Personal Data” in our Platforms Privacy Policy.
3. Personal information that we collect
For information about the categories of Personal Information that we have collected about Consumers in the States listed in this Supplement in the past 12 months please refer to section 4 “What Personal Data do we collect and for which purposes?” in our Platforms Privacy Policy.
As a general policy, Adsquare requires its Data Providers to only supply Personal Information, collected with the Consent of the Consumer according to the applicable law. Regarding Sensitive Personal Information, Adsquare processes Precise Geolocation Data exclusively based on explicit Consent.
Please find below a table to facilitate your understanding of the categories of Personal Data that collect from users by third parties that we process through the Adsquare Platforms.
4. Use of personal information
For information about how we use your Personal Information please refer to section 4 “What Personal Data do we collect and for which purposes?” in our Platforms Privacy Policy column Purposes/Use cases.
5. Sharing or sale of personal information
For information about the categories of Personal information that we share and the categories of Third Parties that we share the Personal Information with please refer to section 5 “Who do we share your information with?” in our Platforms Privacy Policy.
Categories of data sold:
- Mobile Advertising IDs
- Date and time of visiting set of locations *
- Cookie information
- Audience segments (Demographics, preferences
* Precise geolocation data such as latitude/longitude is not shared, sold, or provided to any recipient.
7. Your rights
Besides the GDPR rights enounced in our Platforms Privacy Policy (see section 6 “Your rights as a Data Subject”), as a Consumer resident in one of the states listed above you have the following rights:
8. How to exercise your rights
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, writing to our email address privacy@adsquare.com or reach out by phone through our toll-free number 1 (833) 418-0800.
You may present the request by yourself, or you may authorise an agent to submit a request on your behalf (written permission).
To present your request you only need to inform us what is the Mobile Advertising ID (MAID) of your device. For access requests additional information may be necessary to verify your identity, in such case, please only provide the additional information once it is requested by Adsquare.
Adsquare may deny an access request if you fail to provide the requested information regarding the ownership of the mobile device. Adsquare will provide an explanation as to why access has been denied and you have the right to appeal this decision during the following 45 days after receiving Adsquare’s response via email to privacy@adsquare.com
Opt-Out Option Via Advertising ID
To specifically opt-out from our services without changing your device settings, you can use the below Contact Form, or by email to privacy@adsquare.com, 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”
Opt-Out Option 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”
9. How the business responds to Do Not Track -DNT- signals
Adsquare does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on Adsquare’s websites such as social feature may set cookies on a user’s browser and/or obtain information about the fact that the web browser visited a specific Adsquare website from a certain IP address. Third parties cannot collect any other personally identifiable information from Adsquare’s website unless you provide it to them directly.
10. Annual data requests
From January 1, 2023 to December 31, 2023 Adsquare facilitated requests made by Californian consumers who requested their data to be deleted, to access information (“requests to know”), or Do Not Sell requests (“requests to opt-out”). Below are the metrics from the previous calendar year on the totals for each type of request.