Privacy Policy

Effective as of May 25, 2018, Adventive, Inc. (“Adventive”, “our”, “us” or “we”) has updated our Privacy Policy (“Policy”).

Introduction

Adventive is a global provider of digital advertising and data management technology.  Adventive’s services (the “Service(s)”), collectively accessed through the Adventive platform (the “Platform”) allow for the design, creation, publishing, distribution and delivery, optimization, monitoring and reporting of digital advertising.

This Policy details our commitment to protecting the privacy of individuals who visit our Website(s) (“Visitors), who register to use the products or Services (“Subscriber(s),“), which we market through our Website or who view advertisements (“Ads”) displayed to you and served from Adventive (“Viewers”) on behalf of our Subscribers on other websites.  For purposes of this Policy, “you” or “your” refers to any of the Visitors, Viewers, or Subscribers, and the term “Websites” refers collectively to all websites that are owned and operated by Adventive and that link to this Policy.  Please read this Policy carefully to understand our information practices regarding your information, how we collect it, the source of the information, how it is used, and in some instances shared.  If you do not agree with or understand this Policy, your choice is not to use our Website or Services.  By accessing or using this Website or our Services, you are agreeing to be bound by this Policy.

‍

Personal Information

In this Policy, “personal information” means information relating to an identified or identifiable natural person.  An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or other online identifier. The use of this information collected through our Services shall be limited to the purpose of providing the Service for which the Subscribers have engaged.

Terms of Use of the Adventive Website

This Policy is incorporated into the Adventive Terms and Conditions for visitors of the Adventive Platform, which is available at https://www.adventive.com/legal/terms-conditions/

Scope

This Policy applies to the handling of personal data by Adventive that Adventive collects on or through its Platform and for its own purposes, or when individuals interact when the Platform, for example by using the Adventive website or sending Adventive their information.

This Policy does not apply to the collection or processing of personal data that occurs when our Subscribers use the Service for their own purposes.  The collection and processing of personal data by our Subscribers when they use our Service is subject to the privacy policy of these Subscribers, as posted on their websites. We do not control the type of information that our Subscribers may choose to collect or manage using our Service. That information is owned by them, and it is used, disclosed, and processed by them, or on their behalf, in accordance to their instructions, and their own policies. We are not responsible for our Subscribers’ use of personal data that they collect using our Service.

With the exception of Account Information collected in connection with a Subscriber’s registration or authentication to our Services (as defined below), this Policy does not apply to our security and privacy practices in connection with a Subscriber’s access to and use of the Services.  These security and privacy practices, including how we collect, store, protect, process and otherwise use electronic data, communications and other data submitted and stored within the Services by a Subscriber (“Service Data”), are detailed in our Master Services Agreement, available here: https://wwww.adventive.com/legal/terms-conditions, or such other applicable agreement between you and Adventive. 

The Adventive Platform

Data Collection and Use

Subscribers to our Services are solely responsible for establishing polices for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, related to the collection and handling of personal information in connection with the Viewers who interact with our Subscriber’s Ads. We have no control over, and are not responsible for, Subscribers’ data collection and/or handling practices. We encourage Viewers to read the privacy statements of these Subscribers.

Adventive has no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services.  If you are an individual who interacts with a Subscriber using our Services (such as a viewer of an Ad unit) and would like to modify your personal information or no longer wish to allow your personal information to be used, please contact the Subscriber directly.

Types of Information Collected

We believe that the means used below for data collection are fair, lawful, and proportional to the legitimate interest and needs of our business, and that our methodology fairly addresses your legitimate rights and expectations in view of the context and purpose for the collection and use of the information collected. However, if you have any concerns or questions or want to withdraw your consent, please contact us at privacy@adventive.com.

Account Information

When Subscribers register for an account to access or utilize one or more of our Services (an “Account”),we ask for and collect certain personal information about you, which includes, your full name, email address, optional title, business name, street address and telephone number. Each Adventive "Account" consists of a collection of users which have access to the Adventive Platform. In order to establish an Account, Adventive collects a signed Master Services Agreement (“MSA”) from the Account contact.  The MSA includes “fields” which are used to create the Account, setup the billing and primary contact information. We ask for and collect personal information about a Subscriber such as one’s name, title, business address, business phone number, and email address as well as certain related information such as your company name, website URL, billing contact information including phone number, address, VAT ID and statement email addresses, and the name, alias, or email address of any individuals that you authorize to access and utilize our Services in connection with your Account

Adventive refers to any information as described above as “Account Information” for the purposes of this Policy. The voluntary submission of Account Information represents you are the owner of such personal information, consent to its submission or otherwise have acquired the necessary consent to provide such information to us.

Platform Ad Data Collection

As it relates specifically to the delivery and performance of our Services on behalf of our Subscribers, and in the course of delivering an Ad to a Viewer via our Platform, Adventive does not intentionally collect information that reveals a Viewer’s real-world identity, such as a Viewer’s name, address or phone number.  When an ad unit is created in our platform, the Subscriber may then choose to serve that ad unit to viewers of their websites, or on an ad network. For each ad unit that we serve on the internet, we collect certain information. Subscribers may implement a data collection form for which the viewer of the Ad chooses to submit personal information, and is therefore providing consent for Adventive to process this information on behalf of the Subscriber.  Adventive collects information about your computer or device through the use of cookies, web-beacons and other similar technologies, as explained further below.  This information is pseudonymous and is not considered to be personal information in most jurisdictions in which we operate. However, in certain jurisdictions, in certain contexts, such information, including an Internet Protocol (IP) address and other pseudonymous information, may be considered personal information.

The information Adventive collects includes common information found in every communication sent via the internet, from which we infer the following: browser type and version, browser language, operating system type and version, device type, Internet Protocol (IP address, Internet Service Provider, generalized geographic location and mobile advertising identifier for mobile devices such as smartphones and tablets.  IP addresses are collected solely for the purpose of providing an aggregated, generalized geographic location heat map of the Ad’s delivery and distribution.

Use of Service Data

We use the information that we collect directly and the information we obtain from third parties to create segments, run analytics, and measure the effectiveness of ads on behalf of Adventive’s Subscribers.  We also use this information to improve our Platform and the products and services that we provide to our Subscribers, and to create new products and services.

Cookies, Web Beacons, and Other Ad Targeting Technologies

Adventive utilizes “cookies”, mobile advertising identifiers, and other technologies to enhance our Subscribers experience with the Platform, to deliver more relevant ads, and for ad delivery and reporting via the Platform.

Adventive utilizes these technologies to help recognize a computer or device so that we and our Subscribers are able to deliver the appropriate advertisements to you, measure the impact of that advertising and to better understand and recognize digital media usage patterns.

Technologies used in the Platform include: 

·       Cookies – Cookies are small files, typically of letters and numbers, downloaded onto your computer or mobile device when a Viewer visits certain websites. When a Visitor returns to the websites that deposited cookies on a Viewer’s device – or visit other websites that use the same cookies – the websites recognize such cookies and a Viewer’s browsing device.

o   In some countries, we are not permitted to send cookies (e.g., profiling) other than necessary cookies to the browser of a Visitor without the prior consent of the affected Visitor. In this case, we will seek such consent. The remainder of this section assumes that either the use of cookies is not restricted by applicable law, or if it is restricted, that the individual has explicitly consent to the use of cookies.

o   Adventive uses cookies to uniquely identify an Internet browser.  Certain browsers or browser settings can sometimes block cookies, and cookies may not effectively work on some mobile devices.

·       Pixel Tags – Pixel tags (commonly known as web-beacons) are transparent images, iFrames or JavasScript that we and our Subscribers use to understand how a Viewer interacts with our ads.

We believe that the means used for the above-identified cookies and pixel tags are fair, lawful, and proportional to the legitimate interest and needs of our business, and that our methodology fairly addresses each Viewer’s legitimate rights and expectations in view of the context and purpose for the collection and use of the information collected. However, if you want to prevent the use of certain cookies or pixel tags, you can do so by emailing us at privacy@adventive.com. For more information, see our Cookie Policy on our website at https://www.adventive.com/legal/cookie-policy/.

Data Retention on the Platform

Adventive will retain Account Information from Subscribers for as long as the Subscriber’s Account is active with us or for as long the Subscriber is utilizing our Services.  After you have closed Your Account with us, or ceased utilizing our Services, we may retain and use a Subscriber’s personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

A subscriber can request the deletion of their personal information at any time, and we will consider the request in accordance with applicable laws.

When we have no justifiable business need to process personal information, we will delete it, or if it not possible (for example, because the personal information has been stored in back-up archives), we will securely store the personal information and isolate it from any further processing until deletion is possible

Information collected in the delivery of Ad units is maintained for a minimum of 18 months, however, may be maintained and accessible until such time as the Subscriber has ceased utilizing our Services, or, may be maintained for Compliance with Laws and Law Enforcement Requests as described further below.

The Adventive Website, www.adventive.com

Information Collected From Website Visitors

Website Visitors may submit personal information such as a name, address, phone number and email address when submitting web forms on our Websites for the purposes of requesting customer support, sales support, or general contact or communication requests.  

Automatically Collected Information

We gather certain information and store it in log files when Website Visitors interact with our Websites and Services.  This information includes IP addresses, browser types, referring and exit URLs, operating systems, date and time stamps, locale, languages, status codes, and interactions with the Website and Services. Adventive uses this information from the Website log files to determine how a Website Visitor arrived at our Website, what the Visitor’s interests are regarding our services, and how to further improve our site and our services towards Visitors.

Forums and Knowledge Bases

We may offer publically accessible blogs, Subscriber and community forums and knowledge bases which provide comment sections, discussions or other interactive features.  Visitors should be aware that any information that you post in these areas can be read, collected and used by others who access it and may be indexed or archived by search engines and other web crawlers of which Adventive has no control.  If you wish to update your information, or remove and delete your information please contact privacy@adventive.com. If we are unable to remove and delete your personal information, we will inform you of our inability to do so, and the reason.

‍

Information applicable to both our Website and Platform

How We Use Information

Adventive the information we collect about you (including personal information, to the extent applicable), for a variety of purposes, which may include (a) providing, operating, maintaining, improving, and promoting the Services; (b) enabling the Subscriber access to and use of the Services; (c) sending transactional messages, including support and sales related communications, technical notifications, security alerts and administrative communications including invoices and statements; (d) sending marketing communications, including information about products and services, features, promotions and events, newsletters and surveys, information about Adventive or our partners (to the extent permitted by applicable law). (e) monitoring and analysis of usage trends and activities as in relates to the Websites or Services; (f) preventing unauthorized or fraudulent use of the Services, or other illegal activities; and (g) for other purposes which we obtain your explicit consent.

You may opt-out of receiving marketing communications from Adventive by following the unsubscribe process included with all marketing communications, or by contacting us at privacy@adventive.com.  You may not opt-out of receiving mandatory service communications including, but not limited to (a) System maintenance notifications, service degradation or outage notifications; (b) electronic statements, invoices, late notices and other billing related communications; (c) security alerts; and (d) legal communications.

Links and other websites

This Policy applies solely to the Website and Platform. Adventive’s Website may contain links to other websites, and the Ads delivered by the Platform may run on a variety of other websites.  The information practices and the content of such other websites are governed by the privacy statements of such other websites.  Please be aware that Adventive does not control these third party websites, ads and cookies and is not responsible for the privacy practices of such other websites.  We encourage you to review the privacy statements of such other websites to understand their information practices.

Children’s Personal Information

Adventive’s Website and Services are not intended for children under 13 years of age.  Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowing request or collect any personally identifiable information from anyone under the age of 13.  Any person who visits the Adventive Website, or provides their personal information to Adventive through our Websites represents that they are 13 years of age or older.  If we learn we have collected or received personal information from a child under 13, we will delete that information immediately.  If you have reason to believe that a child under the age of 13 has provided personal information to us through the Websites or Services, please contact us at privacy@adventive.com.

Cross Border Data Transfer

We provide a global Platform and Service. Subject to applicable law, information that we obtain from or about you may be processed or transferred to data centers located throughout the world. The standards and laws that apply to the protection of personal data in these countries might be different from that which is afforded in the country where you are located.

Data Security and Integrity

Adventive implements technical and organizational measures to safeguard data in our possession against

unauthorized or unlawful access, use, modification, processing or disclosure, and against accidental loss, destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody. No data transmission over the Internet can be guaranteed to be completely secure.  We limit access to your personal data to only those employees and third parties who reasonably need access to it to perform the activities attached to their job responsibilities. It may be possible for third parties not under the control of Adventive to intercept,  access, destroy, or alter transmissions or communications unlawfully. While we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us. 

Adventive processes information in a way that is compatible with and relevant for that legitimate business purposes for which it is collected.  To the extent necessary for those purposes, we take commercially reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.  If you have questions regarding the security on the Website, or through the Platform, please contact us at privacy@adventive.com.

‍

Breach of Security

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “How to Contact Us” section.

Lost or Stolen Information.

You must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will assist you in updating your account details.

Data Sharing and Disclosure

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights

We may, in certain situations, be required to disclose personal information in response to lawful requests by public authorities, including to comply with or meet national security or law enforcement requirements.  We may disclose personal information in response to subpoenas, court orders, or legal process to establish or excise our legal rights, or to defend against legal claims.  We may also share personal information if we believe it is necessary in the investigation of, or to prevent illegal activities, fraud, potential threats to the physical safety of any person, the protection of minors, violations of our Master Services Agreement, or otherwise required by law.

Third Party Service Providers

Except as described below, Adventive will not share or disclose your  personal data with third parties. We believe that such practices are fair, lawful, and proportional to the legitimate interest and needs of our business, and that our practices fairly address your legitimate rights and expectations in view of the context and purpose for the collection and use of the information collected, are not intrusive or contrary to your legitimate rights.

If at any time you wish that we cease any activity that affects you, please contact us as indicated in the “How to Contact Us” section.

We share information, including personal information, with our approved third-party service providers that we use for Services delivery such as payment processing, analytics and performance vendors, customer support systems, customer relationship systems, email management vendors and other services.  Approved third-party services may have access to your personal information for the purposes of providing these services.  Adventive does not permit the use of your personal information by third-parties for the purposes of marketing or for any other purpose other than the intended purpose of the service they provide to Adventive.

Subscriber Testimonials

We post testimonials on our Websites or other websites, or in connection with advertising our Services that may contain personal information.  We will obtain written consent to post your name, along with the testimonial.  If you wish to update your information, or withdraw your consent at any time, contact privacy@adventive.com.

With Consent

For all other purposes not explicitly stated above, we may request your consent to share your personal information.

‍

California Residents: Rights Under California Law

Do-Not-Track

Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. California law requires that we disclose to you how we treat do-not-track requests. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law.

In the meantime, there are technical means to prevent some of the tracking, if any. See Section “Cookies.”

Shine the Light

Under California law, a business that has an established business relationship with an individual, and has, within the immediately preceding calendar year, disclosed personal data that is primarily used for personal, family or household purposes to third party for the third party’s direct marketing purposes, must disclose to its California users, upon request, the identity of any such third party, along with the type of personal data disclosed.

You can contact us to as provided in the “How to Contact Us” section. Please note that under California law, businesses are only required to respond to your request once during any calendar year.

EE/EEA Residents: Data Subject Rights under the GDPR

The EU General Data Protection Regulation (GDPR) grants individuals who are in the European Union and European Economic Area (EU/EEA) the following rights, with some limitations. You may contact us, at the address provided in the “How to Contact Us” section below, to exercise any of those rights and we will respond with the requested action or information, or will let you know why that right does not apply to you.

Right Not to Provide Consent or to Withdraw Consent

We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent, and the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of the processing conducted based on consent before its withdraw.

Right of Access

You have the right to obtain confirmation as to whether or not we collect or process personal information concerning you and, if this the case, you have the right to request a copy of such personal information.

Right of Rectification

You have the right to require that we correct any inaccurate personal information concerning you, and that we complete incomplete personal information.

Right of Erasure

In certain circumstances, you have the right to request that we erase personal information concerning you; for example, if it is no longer necessary for the purposes for which it was originally collected.

Right to Restrict Processing

In certain circumstances, you have the right to request that we restrict the processing of the personal information that we have collected about you; for example, where you believe that the personal information that hold about you is not accurate or lawfully held.

Right to Data Portability

In certain circumstances, you have the right to receive the personal information concerning you that you have provided us in a structured, commonly used, machine readable format, and the right to obtain that we transmit the data to another entity where technically feasible.

Right to Object to the Processing

In certain circumstances, you have the right to request that we stop processing your personal information.

Right to Object to the Processing for Direct Marketing Purposes

You have the right to request that we stop sending you marketing communications (i.e., email communications).

Right Not to be Subject to Decisions Based Solely on Automated Processing that Produce Legal Effects

In certain circumstances, you have the right no to be subject to a decision based solely on automated processing - including profiling - that produces legal effects or similarly affects you. 

Right to Complain to a Supervisory Authority

You have the right to lodge complaint with a supervisory authority if you believe that our processing of personal information relating to you infringes the GDPR.

Legal Basis For Processing (European Economic Area Only)

Adventive’s legal basis for collecting and utilizing personally identifiable information of Individuals from the European Economic Area (EEA) will depend on the personal information concerned and the specific context in which the information is collected.  We will normally collect personal information from you where (a) you have provided your consent to do so, (b) we need the personal information to deliver Adventive Services, (c) we have a legal obligation to collect personal information from you, or (d) where the collection and processing of the personal information is in our or a third-party’s legitimate interests, which shall not be overridden by your data protection interests or fundamental rights and freedoms.

Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time.  The withdrawal of consent shall not affect the lawfulness of the processing based on consent prior to its withdrawal.

Should you have additional questions or require further clarification concerning the legal basis for which we collect and use your personal information, please contact us at privacy@adventive.com.

Your Rights

Upon request we will provide you with information about your personal information that we hold or process.  Requests for this information can be made by contacting privacy@adventive.com.  Subscribers to our services may update or change their Account Information using the profile editing utility within our Services, or by contacting support@adventive.com.  To request to have personal information maintained by us returned to you, or removed, please email privacy@adventive.com. Requests to access, change or remove your information will be handled within thirty (30) business days from the date of the request.

Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any entity that acquires all or substantially all of our business, stock, assets, or with whom we merge.

 Policy Updates

Should Adventive make any material changes to this Policy, you will be notified by our positing of a notice on the Websites as well as an email communication to your registered Subscriber account email address prior to the changes becoming effective.  We encourage you to periodically review this page for the latest information on our privacy practices.  Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy.  The sole remedy, if you do not accept the terms of this Policy, is to discontinue the use of the Websites or Services.

Contacting Adventive

Should you have any questions regarding this Policy or Adventive’s privacy practices, please contact us by email at privacy@adventive.com or at:

Adventive, Inc.
Attn: Privacy Department
140 Allens Creek Rd, STE 220
Rochester, NY 14618
United States

Changes to this Privacy Policy

We reserve the right to modify this Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. We may also notify you by sending an email (if we have your contact information). If we make changes, we will notify you by revising the date at the top of this Policy. If you continue to use our services after receiving the notice of changes, you acknowledge that you consent to the updated Policy.

If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you. However, in the event of an acquisition or merger, we would provide notification of this change on our website.

How to Contact Us

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Privacy Compliance Officer at privacy@adventive.com or by mail at:

Adventive, Inc.
Attn: Privacy Department
140 Allens Creek Rd, STE 220
Rochester, NY 14618
United States

To exercise any of your rights as described in “Data Subject Rights under the GDPR”, please contact us in writing, via email or postal mail as indicated above, so that we may consider your request under applicable law. Please be aware that your request will not be accepted for review unless you provide the following:

-        The name, email address, or other identifier that you have used to purchase our products, or if you have not otherwise previously interacted with us, your first and last name and an address where we can correspond with you.

-        State or Country in which you are located.

-        Clear description of the information or content you wish to receive or to be deleted or corrected, or the action you wish to be taken; and

-        Sufficient information to allow us to locate the content or information to be deleted, removed or corrected

For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request.

In addition, please note that, depending on the nature of your inquiry, request or complaint, we may need to verify your identity before implementing your request and may require proof of identity, such as in the form of a government issued ID and proof of geographical address.

We will try to comply with your request as soon as reasonably practicable. However, we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or, in some cases, to charge a fee that takes into account the administrative costs for providing the information or the communication or taking the action requested.