Privacy Policy

Ad Delivery Reporting Across Multiple Sites

As part of our ad tracking and reporting, we log page views and collect information for the purpose of providing media analytic services, including tracking types of access device and connection speed, statistical reporting in connection with the dimensions, position of and duration of an ad on a website, and tracking the number of ads served at a particular time to a particular website. To do so, we collect information about the type of browser and operating system of website visitors, as well as the domain name, day and time of visit, and URL(s) visited. We do so across multiple web domains owned or operated by different entities (each, a “Site”).

Internet Technology

We collect the information described above by using web beacons and log files. We often engage or cooperate with service and technology companies to collect this information. While this tracking and collection technology is commonly used, you might not be familiar with it, and we would like to explain it:

“Web beacons” are electronic files used to track your navigation of the web page on which you saw a given ad that Adelaide is set to track. We do not use web beacons for their other typical purposes, such as the completion of transactions, and submittal of applications.

“Log files” track actions occurring on websites and collect data including your IP address, browser type, referring/exit pages, platform type, date/time stamp, and types of advertisements viewed.

Adelaide does occasionally work with a third party to send consumers an in-browser survey, that is unobtrusive and optional, for quality purposes.

We use the information we collect to determine which media is best at yielding a quality and efficient experience with online ads, to assist us in improving the operation of our services, to maintain the quality of our services, to enhance our services to our business partners and clients, to provide general statistics to our business partners and clients regarding use of Adelaide’s services, and for the other purposes described below.

Personally Identifiable Information

Adelaide does not collect or use Personally Identifiable Information (PII) common to Interest-Based Advertising (IBA). PII is any information that identifies you or can be used to identify you. This includes, but is not limited to, your name, telephone number, address, email address, and date of birth. Adelaide does not collect PII.

Adelaide will not collect PII unless you choose to provide it to us, such as if you choose to do so as part of your interaction with Customer Forms, or Employment Forms, on the Adelaidemetrics.com corporate site.

Examples of such Customer or Employment Forms include but are not limited to: registration forms to access Adelaide published white papers or Adelaide produced webinars, forms providing customer contact information when requesting information from Adelaide and forms to apply for open employment opportunities within Adelaide.

Customer or Employment Forms are not intended for use by individuals under the age of 18 or those who are not residents of the United States. If you are not 18 years of age or older and a resident of the United States or you do not agree with the terms of this Privacy Policy, do not provide us with any information or use any of the Customer Forms.

Non-Personally Identifiable Information

Non-Personally Identifiable Information or Non-PII is data that is linked or reasonably linkable to a particular computer or device, but is not PII, including, but not limited to: your IP address, web pages which you have viewed, and your responses to surveys. This information may be collected using different types of internet technologies, such as cookies (see “Internet Technology” above for more details).

Adelaide may collect this information when you are visiting the Adelaide corporate site or any website where we track the ads of Advertisers. However, this information is not combined with PII.

Information Obtained from Other Companies

We license and otherwise obtain Non-PII from various other companies, including research companies, data aggregation companies and other third-party companies. Data sets may include information about you that such companies have licensed, purchased or collected. We use this information for all the purposes described in this Privacy Policy, and for any other purpose that we choose.

Sharing Your Information

Adelaide may use and share your information: (1) to enable third party service providers to assist or facilitate in the services we provide to our clients; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (3) to enforce our terms of use or to protect our rights; (4) to protect the safety of members of the public and users of our services; (5) with third party marketing partners; (6) with third party research companies, vendors, administrative service providers, technology providers, and selected partners for data validation, aggregation, enhancement, verification and suppression purposes, and for research, marketing, advertising, and data aggregation purposes; (7) for the purposes described elsewhere in this Privacy Policy; or (8) for any other purpose for which you provide consent. Generally we expect these uses to occur within the limited scope of service and activities as described above.

Information provided on Employment forms are only used internally by Adelaide and may disclose PII to third parties under the following circumstances (1) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of Adelaide; (c) prevent a crime or protect national security or (d) protect the personal safety of the users or the public.

Corporate Changes

In the event that Adelaide is acquired by or merged with a third-party entity, we reserve the right to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.

Information Collected by Third Party Sites

Please be aware that the Sites of our advertiser clients as well as the Sites on which we track advertisements or any Site linked to from one of our websites also may collect information from you. These are independent third parties, not affiliated with Adelaide, who we do not form any collaborative nor meshed service offering.  Although we choose our business partners and clients carefully, Adelaide is not responsible for the privacy practices of websites operated by such third parties. You should check the applicable privacy policies of such websites you visit to determine how they handle any information they collect from you, and the scope of that information. We make you aware of these third parties as a courtesy.

Data Retention

Our survey partner may use cookie technology, for purposes outlined above. If you have cookies disabled, if you delete your cookies, or if other software deletes the cookies used for that data storage, such data is lost because it is not retained separately by Adelaide. The cookies that store data will in any case expire, at latest, one year after the last time such information is stored, barring any technical malfunction.

Adelaide retains information regarding ad delivery (see, “Ad Delivery & Reporting” above) until such time as we delete it. Adelaide may delete any or all of IBA or information regarding ad delivery that relates to you at any time and in Adelaide’s sole discretion, notwithstanding its normal data retention policies. Further, Adelaide reserves the right to retain and use any information described in this Privacy Policy as reasonably necessary to comply with laws or regulations, notwithstanding any limitations described in this Privacy Policy to the contrary. If Adelaide changes its data retention policies by updating this Privacy Policy, its new policies will apply to all data collected after the effective date of those changes.

Children’s Privacy

Adelaide is very sensitive to the issue of children’s privacy. Adelaide’s products and services are neither developed for, nor directed at, children. Adelaide does not employ or offer advertising targeting towards children under the age of 13. If you believe your child has provided us with PII through the Adelaide corporate site or through our corporate marketing materials, please contact us and we will delete any such data.

Security

Adelaide employs industry-standard measures to ensure the security of all information. We routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume these risks when communicating with us.

Jurisdictional Issues

The Site and information we maintain is controlled, stored and operated within the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. By using this Site and submitting any information you consent to the transfer and storage of information to the United States.

Changes

Adelaide may find it appropriate or necessary, or may be legally obligated, to update this Privacy Policy from time to time. When we do, we will post those changes on this page and update the effective date (found at the bottom) so that you have a way to always become aware of the information we collect, how we use it, and under what circumstances we disclose it. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of information you have already provided to us, we will attempt to obtain your consent (if we have the necessary contact information) before implementing such revisions with respect to such information, or notify you either by placing a prominent notice on the home page of our website or by directly sending you a notification. For all other changes, it is your responsibility to review this Privacy Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often.

YOU UNDERSTAND AND AGREE THAT ADELAIDE’S LIABILITY FROM ANY DISPUTE OVER PRIVACY OR THIS PRIVACY POLICY WILL BE LIMITED AS SET FORTH IN THE TERMS AND CONDITIONS OF OUR APPLICABLE WEBSITE TERMS AND CONDITIONS.

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Privacy Policy For Residents Of European Economic Area

1. Introduction

Adelaide (“Adelaide”) is a digital media technology company that may track

advertisements to the websites you visit. Adelaide understands that your online privacy is important to you. We have created the following Privacy Policy for those who live the European Economic Area (“EEA”) and subject to General Data Protection Regulation (“GDPR”) to let you know what information we collect on the Adelaidemetrics.com website, when you visit our customers’ (referred to as “Advertisers”) digital ads, how such information is used, and how it is shared with third parties if shared at all.

1.1 We are committed to safeguarding the privacy of our website visitors. To this end, we minimize the amount of data we collect, to the essentials.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data. This is not the majority of our business activity.

1.3 This policy also applies where we are acting as the data processor.

1.4 By using our direct website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. We do not use cookies in other situations.

1.5 Our systems incorporate privacy controls which affect how we will process your personal data.

1.6 The terms “you,” “your,” and “yours” refer to the website visitor or consumer. The terms “Adelaide,” “we,” “us,” and “our” refer to Adelaide, the digital media analytics platform, and its related services (collectively, “Adelaide Entities”). For more information about us, see Section 12.

2. How We Use Your Personal Data

2.1 In this Section 2 we have set out in accordance to Article 6(1)(f), 13 and 14 of the GDPR: (a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing.

2.2 We may process data about your use of our website and services ('usage data'). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is through log files, web beacons. This usage data may be processed for the purposes of analyzing the use of the website and services, to improve your quality and efficient experience with online ads. The legal basis for this processing is monitoring and improving our website and services and web analytics. We minimize the amount of time we need to store any personal data.

2.3 We may process information contained in or relating to any communication that you send to us as part of your interaction with any customer forms on our website ('correspondence data'). Examples of such communication include but are not limited to: registration forms to access Adelaide published white papers or Adelaide produced webinars, forms providing customer contact information when requesting information from Adelaide. The correspondence data may include your name, telephone number, address, email address, the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communication with users in response to their correspondence.

2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ('notification data'), such as when we stay in touch after a live event. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.5 We may process information contained in any application of employment you submit through our website ('employment data'). The employment data may include your name, address, phone number, email address and employment history. The employment data may be processed for the purposes of evaluating your employment eligibility. The legal basis for this process is our legitimate interest, namely the proper administration of our business in fulfilling an open employment opportunity within Adelaide.

2.6 We do not process personal data as any part of our reporting to our Advertisers.

2.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.8 We do not process special categories of personal data as defined in Article 9 of the GDPR (https://gdpr-info.eu/art-9-gdpr/)

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3. Providing Your Personal Data to Others

3.1 We may disclose data we collect to any member of our group of companies (this means our subsidiaries and affiliates) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose ad data we collect to third parties in order to verify the data we have received and to perform web analytics for the purpose, and on the legal bases, set out in this policy.

3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

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4. International Transfers of Your Personal Data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside EEA. Data transferred is aggregated and no longer personally identifiable, nor personal.

4.2 We only have one office and it is in the United States. The European Commission has made an 'adequacy decision' with respect to the data protection law. Transfers to each of these countries from our data storage facilities will be protected by appropriate safeguards, and the use of standard data protection clauses adopted or approved by the European Commission, where appropriate, a copy of which can be obtained by sending a request to privacy@adelaidemetrics.com.

4.3 The hosting facilities for personal data are situated in Germany. The European Commission has made an 'adequacy decision' with respect to the data protection laws in Germany. Transfers will be protected by appropriate safeguards, or the use of standard data protection clauses adopted or approved by the European Commission, where appropriate, a copy of which can be obtained by sending a request to privacy@adelaidemetrics.com.

4.4 When possible, all analytics of personal data will be done within EEA by external third party and only highly level summary data which does not contain individual personal data will be transferred outside the EEA. Transfers to third parties will be protected by appropriate safeguards, namely through secure servers and the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from privacy@adelaidemetrics.com.

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5. Retaining and Deleting Personal Data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes as described in Section 2.

5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

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6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

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7. Your Rights

7.1 In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data after you have provided the appropriate evidence of your identity such as a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can send a request through privacy@adelaidemetrics.com.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the removal of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.8 To the extent that the legal basis for our processing of your personal data is consent and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence.

7.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.11 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

7.12 You may exercise any of your rights in relation to your personal data by written notice to us and sending such notice to privacy@adelaidemetrics.com.

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8. About Log Files, Web Beacons, and Cookies

8.1 Log files track actions occurring on websites and collect data including your IP address, browser type, referring/exit pages, platform type, date/time stamp, and types of advertisements viewed.

8.2 Web beacons are electronic files used to track your navigation of the web page on which you saw a given ad that Adelaide is set to track. We do not use web beacons for their other typical purposes, such as the completion of transactions, and submittal of applications.

8.3 Adelaide (as a processor) does occasionally work with a third party (the controller) to send you an in-browser survey, that is unobtrusive and optional, for quality purposes. Not all people who see an ad that Adelaide interacts with will get a cookie. We abide by the cookie policies of the third-party that helps us with this, and we audit them for safe handling of cookie data. The cookie will only be used for the purposes of this momentary quality survey. You can learn more about cookies on the Internet Advertising Bureau’s website: http://www.allaboutcookies.org.

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9. How We Use Log Files and Web Beacons

9.1 We use log files, web beacon for to determine which media is the best at yielding a quality and efficient experience with online ads, to assist us in improving the operation of our services, to maintain the quality of our services, to enhance our services to our business partners and clients, to provide general statistics to our business partners and clients regarding use of Adelaide’s services.

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10. Managing Cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

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11. Our Details

11.1 This website is owned and operated by Adelaide.

11.2 We are registered in the United States and our registered office and principal place of business is at Adelaide, 622 Greenwich St. 5D, New York, NY 10014.

11.3 You can contact us: (a) by mail at the address given above; (b) using our website contact form; (c) by telephone - +1 732-474-8373; or (d) by email at privacy@adelaidemetrics.com.

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12. Data Protection Officer

12.1 Our data protection officer is Diane deCordova, COO. You can contact our Data Protection Officer using the methods in Section 13.

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13. Contact Us

If you have questions about this Privacy Policy, the practices of or your dealings with us relating to this Privacy Policy, please email us at privacy@adelaidemetrics.com or you can send correspondence to us at the following address:

Adelaide Metrics Inc.
Attn: Chief Operating Officer
622 Greenwich St. 5D
New York, NY 10014

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