Platform Privacy Policy
This Platforms 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” have the meanings given in the EU General Data Protection Regulation.
If you reside in the United States of America, please visit our US Privacy Supplement section.
1. What we do
Adsquare offers digital advertising technology platforms that facilitate the creation and execution of targeting, measuring, and analysing digital and location-based advertising campaigns. It provides transparent and neutral data exchange platforms that bring 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. For example, an opt-out from targeting would not reduce the number of ads, it just makes the ads you receive less relevant.
The platforms have been built mobile-first in Germany with user privacy at the core of its design from day one.
In a nutshell:
- Adsquare does not collect the Personal Data that is processed for providing its products and services through our platforms. Adsquare’s platforms process the Personal Data provided by third-party data partners which have chosen to cooperate with Adsquare.
- Third party 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 platforms allow 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 more relevant advertising, e.g. based on your interests and affinities.
- This data uses advertising identifiers associated with your mobile device rather than names, e-mail addresses or phone numbers.
- For some services such as Measurement, Attribution 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 ID-based Activation, Measurement, Attribution and Analytics 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” (Link) heading below.
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.
- Third party data 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.
At Adsquare, we fully respect your right of informational self-determination. Therefore, we require our clients and partners to satisfy all transparency disclosures and consent requirements before processing their data.
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 Platforms | 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 Platforms | 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 Platforms and Adsquare. |
| Adsquare Platforms Google Analytics (Processor) | IP address of the client that accesses the Platforms |
|
| Intercom (Processor) |
Regarding Clients that accesses the Platforms
|
|
| Permitted purpose | Types of personal data | Description | Legal basis for data collected in the EEA |
|---|---|---|---|
| TCF 2. Use limited data to select advertising |
|
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.
|
Consent |
| TCF 3. Create profiles for personalised advertising |
|
Information about your activity on this service can be stored and combined with other information about you or similar users. This is used to:
|
Consent |
| TCF 4. Use profiles to select personalised advertising |
|
Advertising presented to you can be based on advertising profiles reflecting your activity, interests and personal aspects.
|
Consent |
| TCF 5. Create profiles to personalise content |
|
Information about your activity can be stored and combined to:
|
Consent |
| TCF 6. Use profiles to select personalised content |
|
Content presented can be based on content personalisation profiles.
|
Consent |
| TCF 7. Measure advertising performance |
|
Information about advertising interactions can be used to determine campaign effectiveness.
|
Consent |
| TCF 8. Measure content performance |
|
Information about content interactions can be used to measure relevance and effectiveness.
|
Consent |
| TCF 9. Understand audiences through statistics or combinations of data from different sources |
|
Reports can be generated to identify common audience characteristics.
|
Consent |
| TCF 10. Develop and improve services |
|
Data can be used to improve existing products and develop new services.
|
Consent |
| TCF 11. Use limited data to select content |
|
Content presented can be based on limited data such as website/app used, non-precise location, device type or content interactions. | Consent |
| TCF Special Purpose 3. Save and communicate privacy choices |
|
Privacy choices are saved and communicated to enable compliance with consent and transparency requirements.
|
Legitimate Interest |
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 at www.adsquare.com/privacy/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 to 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 contacting us using the contact details provided under the “Send us your privacy request” heading below.
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.
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 reside in the United States of America, please visit our US Privacy Supplement section. (Link).
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 12 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 12 months. In other words, any data that can be related to your internet devices are deleted after a maximum of 12 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 contacting us using the contact details provided under the “Send us your privacy request” heading below.
9. Legal basis for processing (EEA Data Subjects 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.
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 Personalization
- 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 “Contact Us” 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
* 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.