1. ABOUT US

Our websites https://adlane.info/, https://adlane.io, and all https://adlane.info/, https://adlane.io subdomains (also “Our Websites”) are owned and operated by Adlane LTD, a company registered in Bulgaria under registration number 204945250 as a limited liability company having its registered office in Burgas province, Burgas, 8000, 10 Apostol Karamitiev Str., floor 5, office 13 (also referred to as “Adlane”, “We”, “Our” and “Us”).

Adlane is a powerful self-service advertising network providing comprehensive and industry-leading technologies for website monetization, as well as CMP service (the “CMP”) provided to assist publishers in obtaining consent for the data collection (together the “Services”).

Our data protection team can be contacted at dpo@adlane.info or legal@adlane.io

This Privacy Statement applies only to Your use of Our Websites and Services. It does not extend to any websites that are linked to Our Websites (whether We provide those links or whether they are shared by other users). We have no control over how Your data is collected, stored, or used by other websites and We advise You to check the privacy statements of any such websites before providing any data to them.

This Privacy Statement applies to:

• Our Websites visitors;
• Our customers (including their internal users);
• End-users of Our customers who interact with Our customers on their cookie profiles on advertising platforms,

(jointly referred to as “Users”, “You”, and “Your”).

Adlane recognizes Your right to confidentiality and is committed to protecting Your privacy. This Privacy Statement discloses what data We gather, how We use it, and how to correct or change it. You can expect to be hereby notified of:

• What personally identifiable data of Yours is collected;
• Who is collecting the data;
• How the data is used;
• With whom the data may be shared;
• What choices do You have regarding the collection, use, and distribution of the data;
• What kinds of security procedures are in place to protect against the loss, misuse, or alteration of the data under Our control;
• How You can correct any inaccuracies in the data.

If any additional questions arise, You should direct them to Our data protection team reachable at dpo@adlane.info or legal@adlane.io

2. YOUR PERSONAL DATA

All personal data is processed and stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and other international legislative acts concerning data protection, including but not limited to US privacy legislation. For more information about the data processing of US residents and all applicable laws therein, please visit Our US Residents Privacy Notice.

We collect personal data on the basis of consent obtained from the Users who have reached eighteen (18) years of age.

We do not collect and/or process sensitive data, which means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Under GDPR We ensure that Your personal data is processed lawfully, fairly, and transparently, without adversely affecting Your rights. We will only process Your personal data if at least one of the following grounds applies:

• You have given consent to the processing of Your personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which You are a party or in order to take steps at Your request prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which We are subject; and/or
• Processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

We use Your data to provide the best possible Services to You. This includes:

• Providing and managing Your account;
• Providing and managing Your access to Our Services;
• Personalizing and tailoring Your experience on Our Websites;
• Supplying, personalizing, and tailoring the Services for Your benefit;
• Responding to communications from You (to contact You about Your account and provide customer support, including responding to Your comments and questions);
• Keeping You informed about the service, features, surveys, newsletters, offers, and events We think You may find useful or which You have requested from Us and/or that You have subscribed to (You may unsubscribe or opt-out at any time by changing Your email preferences link in emails);
• Selling and marketing the Services;
• Diagnosing Your needs and problems, analyzing trends, improving the features and usability of the Services, and better understanding Our customers and Users;
• Analyzing Your use of Our Websites to improve Your User experience;
• Identification when You log in to Your account.

We do not collect personal data when You visit Our Websites unless You sign up for a service, place an order, register, complete a survey, or subscribe to the newsletter. When You visit Our Websites, We also may collect certain data by automatic means that may include Your IP address; Your web browser type and version; Your operating system; a list of URLs starting with a referring site, Your activity on Our Websites, and the site You exit to.

In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the Services We can provide You without Your consent for Us to be able to use such data.

When You sign up for a service, We will ask You for the following personal data: name, surname, Your company, billing address and details, skype contact, and e-mail address. We may use Your personal data to contact You for account purposes.

When You register an account or place an order (upgrade to a paid version of the software provided within Our Services), We will ask You for the following personal data: name, surname, e-mail, billing address, mailing address, job title, company, phone number, skype contact and banking details. This data is requested to verify Your identity. This data is transmitted via a secure encrypted server using Transport Layer Security (TLS) encryption, more commonly known as HTTPS, the approved industry standard (see Security section below). We may use Your personal data to contact You for account purposes.

When You submit feedback or questions via e-mail or contact Us for information about Our Websites, We will request Your name, company, messenger contact, and e-mail address. We use this data solely to respond to Your inquiries.

When You subscribe to a newsletter, We will request Your name and email address. We use this data to provide You with the news and information according to Your subscription. You can revoke Your consent to receive a newsletter at any time and Your subscription will be canceled.

When You visit the Property in the meaning of the CMP Terms of Service and it uses Our CMP, it may store or retrieve information on your browser, your preferences, or your device. Thus, we may use limited data to select advertising; create profiles for personalized advertising; use profiles to select personalized advertising; create profiles to personalize content; use profiles to select personalized content; measure advertising performance; measure content performance; understand audiences through statistics or combinations of data from different sources; develop and improve services; use limited data to select content; use precise geolocation data; actively scan device characteristics for identification.

All performance statistics and data are kept private and any personally identifiable data is not released to any of Our partners without Your permission. Occasionally, We may reference Our own statistics, but the data will be an aggregate of Our whole client base, without any party’s identification provided.

With Your permission and/or where permitted by law, We may also use Your data for marketing purposes which may include contacting You by email with information, news, and offers on Our Services. We will not, however, send You any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect Your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.

ALL PERSONAL DATA RELATING TO OUR CUSTOMERS AND CLIENTS, INCLUDING NAMES, EMAIL ADDRESSES, AND OTHER PERSONAL DATA, IS KEPT SECURE AND CONFIDENTIAL. WE DO NOT SHARE, SELL, RENT, OR BARTER ANY IDENTIFIABLE PERSONAL DATA TO ANY THIRD PARTY WITHOUT YOUR PERMISSION.

3. YOUR RIGHTS UNDER GDPR

Our Privacy Statement provides You with the opportunity to exercise the following rights You have Under the GDPR as a data subject:

• the right to be informed of what data processing is taking place;
• the right to request access to, deletion of, or correction of Your personal data;
• the right to restrict the processing of Your personal data;
• the right to data portability;
• the right to object to the processing of Your personal data;
• the right to complain to a supervisory authority;
• the right to refuse automated decision-making and profiling.

To enforce any of the foregoing rights please contact Our data protection team at dpo@adlane.info or legal@adlane.io.

In case any of Your personal data is used by Adlane for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision by Adlane.

The right described in the section above, however, does not apply in the following circumstances:

• The decision is necessary for the entry into or performance of a contract between You and Adlane;
• The decision is authorized by law; or
• You have given Your explicit consent for such automated decision-making.

We currently use NO automated decision-making for any purpose.

We currently profile personal data for the purposes of marketing and advertising. Where We use personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences;
• Appropriate mathematical or statistical procedures will be used;
• Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and
• All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

4. DATA COLLECTION, STORAGE, AND TRANSFER

All the data collection on Our Websites and through the Services is carried out in a manner clear and transparent to Our Users. Adlane does not affix any spybot or data collection software to any of its products.

We only keep Your data for as long as needed in order to use it for the purposes set in Section 2, and/or for as long as We have Your permission to keep it. In any event, We are conducting an annual review to ascertain whether We need to keep Your data. Your data will be deleted if We no longer need it.

Adlane primarily stores data about customers and site visitors in the European Economic Area (“EEA”). To facilitate Our global operations, We may transfer and access such data from around the world, including from other countries in which We are operating. Some or all of Your data may be stored or transferred outside of the EEA. If You are not accepting this, please refer to Our data protection team with the corresponding request at dpo@adlane.info or legal@adlane.io.

If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that Your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage. For more information on international data transfers please get acquainted with Our Data Processing Addendum.

5. SECURITY

Data security is of great importance to Us, and to protect Your data We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through Our Websites and Services.

Steps We take to secure and protect Your personal data include:

• Access to the data stored within Our Websites and Services is restricted to a limited number of Our employees;
• We use industry best practices to keep any data collected and/or transmitted to Our Websites and Services secure. Our Websites and Services are all secured by SSL protocol, which provides encryption to all data transmitted;
• We use Transport Layer Security (TLS) encryption, more commonly known as HTTPS, for all of the data that We send and receive. This ensures that all User data in transit is both safe and secure, and additionally only available to the intended recipients. This ensures that online transactions and the transmission of personal data such as credit card details are safe from third-party interception;
• Our Websites and Services are protected by a) firewalls establishing a barrier between Our trusted, secure internal network and the Internet and b) IP restrictions, limiting access to allowed IPs;
• We use third-party vendors and hosting partners (such as AWS) to provide the necessary hardware, software, networking, storage, and related technology to run the Services. These vendors all offer best-in-class security, You can see Google’s security features here: https://cloud.google.com/security/; Amazon AWS security features here: https://aws.amazon.com/security/;

• We also use third-party vendors to prevent attacks on Our Websites or the Services and the destruction or theft of any data. Such vendors also monitor potential attacks to inform Our customers in the event their content and/or any related data has been compromised;
• We review Our data collection and processing practices periodically and will review and amend this Privacy Statement accordingly.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the Internet may not be completely secure and that You are advised to take suitable precautions when transmitting Us data via the Internet.

6. THIRD PARTIES

We may contract with third parties to supply Services represented on Our Websites to You on Our behalf. These may include payment processing, search engine facilities, advertising, and marketing. In some cases, third parties may require access to some or all of Your data. Where any of Your data is required for such a purpose, We will accomplish this only under Your consent and take all reasonable steps to ensure that Your data will be handled safely, securely, and in accordance with Your rights, Our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of Our Websites including data on traffic, usage patterns, sales, and other data. All such data will be anonymized and will not include any personally identifying data. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances, Adlane may be legally required to share certain data, which may include Your personal data, for example, where there is involvement in legal proceedings, where Adlane is complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from You in order to share Your data in such circumstances and will comply as required with any legally binding request that is made by the competent authorities.

7. TRANSFER OF CONTROL

We may, from time to time, expand or reduce Services represented on Our Websites, and this may involve the sale and/or the transfer of control of all or part of Adlane. Data provided by Users will, where it is relevant to any part of Our business so transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use the data for the purposes for which it was originally collected by Adlane.

In the event that any of Your data is to be transferred in such a manner, You will not be contacted in advance and informed of the changes.

8. COOKIES

To better serve You, We use cookies to reduce the time required to log in as well as for the continuous improvement of Your User experience across Our Websites. Cookies are pieces of data that Our Websites can set on Your browser or device and they can typically be read on future visits to learn about You more and to personalize Your experience, including the ads that are displayed to You.

We collect and process a variety of non-personally identifying data in order to prevent fraud and support and maintain a higher-quality browsing experience for all Users.

To know more about the way, how We process cookies and use such data, please refer to Our Cookie Policy.

9. YOUR CHOICE/OPT-OUT

Adlane provides You with the opportunity to withdraw Your consent for Us to use Your personal data, update, change, or remove Your personal data from Our Websites, and opt out of receiving communications from Us at any time. Please contact Our data protection team with the corresponding request at dpo@adlane.info or legal@adlane.io.

10. CHANGES TO THIS PRIVACY STATEMENT

We may change this Privacy Statement as We may deem necessary from time to time, or as may be required by law. Any changes in force will be posted on Our Websites in a timely manner and You will be deemed to have familiarized with this Privacy Statement during Your first use of Our Websites following the alterations published. We recommend that You check this page regularly to keep up-to-date.

11. CONTACT INFORMATION

If You have any questions or comments about this Privacy Statement, the ways in which Adlane collects and uses Your data described here, or Your choices and rights regarding such use, please do not hesitate to contact Us at:

• Email:  dpo@adlane.info or legal@adlane.io
• Postal Address: Bulgaria, Burgas province, Burgas, 8000, 10 Apostol Karamitiev Str., floor 5, office 13