Privacy Policy

Our commitments to your privacy and security

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) (“Website Visitors”), who register to use the products or Services, which we market through our Website (“Subscriber(s), you”, or “your”), or who view advertisements (“Ads”) displayed to you and served from Adventive on behalf of our Subscribers on other websites.  For purposes of this Policy, the term “Websites” shall refer 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, how it is used, and in some instances shared.  If you do not agree with this Policy, your choice is not to use our Website or Services.  By accessing or using this Website or our Services, you agree to this Privacy Policy.

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 information collected through our Services shall be limited to the purpose of providing the Service for which the Subscribers have engaged.

The Adventive Platform

Data Collection and Use

With the exception of Account Information collected in connection with your registration or authentication to our Services (as defined below), this Policy does not apply to our security and privacy practices in connection with your 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 You (“Service Data”), are detailed in our Master Services Agreement, available here, or such other applicable agreement between You and Adventive.

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 individuals (“Data Subjects”) with whom our Subscriber’s Ads interact with. 

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 which to allow your personal information to be used, please contact the Subscriber directly.

Account Information

When you register for an account to access or utilize one or more of our Services (an “Account”), we ask for and collect personal information about you such as your 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 voluntarily submission of Account Information represents you are the owner of such personal information, content 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 you via our Platform, Adventive does not intentionally collect information that reveals your real-world identity, such as your name, address or phone number.  Subscribers may implement a data collection form for which the viewer of the Ad may voluntarily  submit personal information, and as such is 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 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 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.

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 the better understand an recognize digital media usage patterns.

Technologies used in the Platform include:

·       Cookies – Small text files that contain a string of characters.  Adventive uses cookies to uniquely identify and Internet browser.  Certain browsers or browser settings can sometimes block cookies, and cookies may not effectively 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 ads are interacted with.

 

Data Retention on the Platform

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

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 below.

 

The Adventive Website, www.adventive.com

Information Collected From You

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 you 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 you arrived at our Website, what your interests are regarding our services, and how to further improve our site and our services towards you.

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.  You should be aware that any information that you post in these area can be read, collected and used by others whom 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 your information please contact privacy@adventive.com. If we are unable to remove 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 may use 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 promotional communications, including information about products and services, features, promotions and events, newsletters and surveys, information about Adventive or our partners. (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 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

Data Security and Integrity

Adventive implements technical and organizational measures to safeguard data in our possession against loss, theft, unauthorized use, disclosure or modification.  No data transmission over the Internet can be guaranteed to be completely secure.  It may be possible for third parties not under the control of Adventive to intercept or access 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 purposes for which it is collected.  To the extent necessary for those purposes, we take commercially reasonsable 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.

 

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

We may 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 may 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, contact privacy@adventive.com.

With Consent

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

 

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Adventive complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the United States, respectively.

Adventive has certified to the Department of Commerce that for all personal information it receives from the EU and Switzerland, it will adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access and Recourse, Enforcement and Liability.

If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To find out more about the Privacy Shield List, and find details of our certification, please visit: https://www.privacyshield.gov/list.

Under the Privacy Shield, Adventive may remain liable if its third-party service providers process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Residents of the EU or Switzerland who believe that their personal information has not been processed in compliance with the Privacy Shield Principles may raise their complaint in the following ways:

 

1.     Contact Adventive directly using the details in the “Contacting Adventive” section below.  Complaints will be responded to within fourty-five (45) business days of receipt.

2.     You may further refer unresolved privacy complaints under the Privacy Shield via the Better Business Bureau, an alternative dispute resolution provider located in the United States.  If you do not receive a timely acknowledgement of your complaint or if your compliant is not satisfactorily addressed by us, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint directly with the BBB.

3.     You may further refer your complaint to the U.S. Department of Commerce or the Federal Trade Commission for further investigation.

4.     For residual disputes that cannot be     resolved by the methods above, you may be able to invoke a binding     arbitration process under certain conditions. To find out more about the     Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Federal Trade Commission has investigation and enforcement authority over our compliance with the Privacy Shield.

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