Privacy Policy

WELCOME TO OUR PRIVACY POLICY!

When you visit our site and/or deal with our technologies and services, whether you are a client (i.e. an Advertiser or a Publisher) or an end-user (i.e. a visitor of our site or a visitor/customer of our clients’ sites which show our advertising banners or other ad formats), you will share and/or we will collect/access some personal information about you. Please be assured that we are fully dedicated to the protection of your personal information.

Because your privacy is so important to us, we provide you with this Privacy Policy, explaining how we collect, use and share your personal information, so that you can make informed choices about the use of your data.

Please read this Privacy Policy carefully. You can contact us if you have any question about our privacy practices or about what we are doing with your personal information. We will be happy to provide you any assistance you may need.

1. WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The company which decides how and why your personal data is processed, and which is called “Data Controller” is:
AdSupply Inc. a California corporation having its registered address at 10811 Washington Boulevard, Suite 400, Culver City, California 90232, United States of America, and registered with the California Secretary of State under number C3416158.

 

2. WHAT PERSONAL DATA DO WE PROCESS?

2.1. You are a visitor of Twinred.com or ui.twinred.com

Log data and device information

When you visit our site, we temporarily store log data and information from or about your computer, phone, or other device you use to access or navigate on our site. This includes:

  • your IP address;
  • the date, time and duration of your visit;
  • the hardware, software or internet browser you use;
  • information about your computer’s operating system, like application version;
  • identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
  • the website you were referred from to our website, that is say the referrer URL;
  • the type of device you are using.

Information collected by cookies and other technologies

Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device. To learn more about how we use cookies and your choices, please check out our Cookies Policy below.

2.2. You are an Advertiser or a Publisher

2.2.1. Personal information we get when you register on our site or contract with us

When you register on our site or contract with us, we will need to collect the following personal information about you:

  • Your identification details: your first name, last name company/account name;
  • Your contact information: your email address, and country;

You can also add some optional information, depending on whether you are a Publisher or an Advertiser, for example, your full address or your Skype ID.

2.2.2. Personal information we get when you contact the Twinred Support or communicate with us

We collect all information you choose to share with the Twinred Support, like your personal e-mail, your feedback, comment or request and your conversations with Support.

More generally, when you communicate with us in any other way, we will collect the information you provide us.

2.2.3. Personal Information we get when you are browsing on the Advertiser or Publisher interface

Log data and device information

When you visit our site, we temporarily store log data and information from or about your computer, phone, or other device you use to browse on the Advertiser or Publisher interface.

This includes:

  • your IP address;
  • the date, time and duration of your visit;
  • the hardware, software or internet browser you use;
  • information about your computer’s operating system, like application version;
  • identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
  • the website you were referred from to our website, that is say the referrer URL;
  • the type of device you are using.

Information collected by cookies and other technologies

Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device. To learn more about how we use cookies and your choices, please check out our Cookies Policy below.

2.2.4. Transaction information

We process the information you provide us with for payout or payment and invoicing purposes, depending on whether you are an Advertiser or a Publisher.

If you choose to execute the transaction through a virtual account provider (if available), we will not be responsible for the data you provide to this third party to create and manage your virtual account. Please check directly the privacy policy of the virtual account provider if you want to learn more.

2.3. You are an end-user of one of our client’s website and interact with our technologies and services

If you are an end-user of one of our clients’ websites, the information that we process about you is given through the Clients’ websites where our advertising banners or other ad formats are displayed.

Usage Information
We are processing some information about you, if you are an end-user of one of our clients’ websites when you are visiting a page where the ad is displayed and/or interact with the ads. The information collected includes:

  • the type of advertisement you interacted with;
  • which advertisement you interacted with;
  • the tracking pixel in the advertisement (if any).
  • Your IP address
  • Your User Agent
  • Your Country.

Please however note that your IP address and your User Agent will be anonymized within a short time after the collection.

Information collected by cookies and other technologies

Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device. To learn more about how we use cookies and your choices, please check out our Cookies Policy below.

 

3. WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect for the following purposes:

3.1. You are a visitor of www.TwinRed.com or ui.twinred.com

We collect and process log data and your device information in order to facilitate the use of our site, to ensure the security of our systems and the technical administration of the network infrastructure.

We process this information given our legitimate interest in ensuring the smooth running of our site, as well as, information, system, and network security.

3.2. You are an Advertiser or a Publisher

3.2.1. To open your Advertiser or Publisher account and/or register you as a publisher/advertiser in our system

We use the personal data you give us to create and administer your online account and/or register you as an Advertiser or Publisher in our systems.

We process this information as it is necessary for the adequate performance of the contract we have with you.

3.2.2. Customer relationship management and communication with you

Sharing your personal details with our Support team allows us to respond to any question you might have.

Please note that we may also communicate with you through emails or any other means, if appropriate, in order to inform you of certain changes regarding our site or of some events/actions, for example, when you successfully register on our site.

We process this information given our legitimate interest in improving our users’ experience and delivering appropriate customer services.

3.2.3. Payment and accounting

We use your data for payment/payout and accounting purposes to process transactions and maintain legally required business records.

We process this information, as it is necessary for the adequate performance of the contract we have with you once you register as an Advertiser or Publisher.

3.2.4. Ensure a safe and trustworthy environment

Because we want to create and ensure a safe environment, we use your personal data to detect and prevent fraud and other illegal activities related to the use of our site.

We use your personal information for security purposes and risk assessment, such as to authenticate you on our site and verify your identity.

We process this information given our legitimate interest in ensuring fraud detection and prevention, as well as, information, system, network and cyber security.

3.2.5. Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data, such as for accounting purposes, to respond to requests of competent authorities or to establish, exercise or defend legal claims.

3.3. You are an end-user of one of our client’s website and interact with our technologies and services

The only purpose of the processing of your data is to allocate the successful advertisement to a particular business transaction between Publishers and Advertisers.

We process this information given our legitimate interest in providing ad-tracking services to Advertisers and Publishers in order to display targeted advertising to the end users of our client’s websites.

 

4. HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement serious security measures to grant maximum protection to your personal information against unauthorized access, modification, disclosure or deletion. Your data is always protected by our highly sophisticated security systems.

As regards the data of the end users of our client’s sites, we have implemented a highly secure technology, which anonymizes their personal data in a very short time after the collection.

We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our site and the entire IT infrastructure related to it are updated against the latest network security vulnerabilities. We periodically test our IT systems and do sophisticated penetration tests.

 

5. WITH WHOM DO WE SHARE YOUR DATA?

We share your data with the following parties:

5.1. Entities of our company’s group

We share your personal information with the following companies of our group based in Luxembourg and Hungary as they are helping us to deliver the ad network related services:

  • DuoDecad IT Services Luxembourg S.à r.l., Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler Services S.à r.l., Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Ad Supply Holding S.à r.l., Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler SSC kft, Expo tér 5-7, H-1101, Budapest, Hungary;
  • AdSupply IP Kft., Expo tér 5-7, H-1101, Budapest, Hungary.

5.2. Service providers

We use carefully selected and trusted third parties, who act as service providers.

We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our activity, our third party service providers we are using may regularly change. Such entities mainly belong to the following areas: (a) business intelligence and analytics; (b) customer care/support; (c) fraud detection and prevention.

As regards www.Twinred.com, we are using WordPress.com, which offers the design, features, and support to our site. To learn more about the data they process under our instructions, please check their privacy policy here.

5.3. Payment Providers and financial institutions

If you are an Advertiser or a Publisher, in order to process your payment/execute the payout, you may share certain information with a third party bank or payment processor.

You may receive transactional emails from this party confirming the receipt of your referral fees, including other possible relevant notifications.

If you share information with third parties directly, this Privacy Policy does not govern that information.

We may furthermore share information with relevant financial institutions or payment processors, if we consider it strictly necessary for fraud detection and prevention purposes.

5.4. Law enforcement agencies or governmental authorities

We may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our Terms of Service, and/or (d) protect our rights or defend ourselves against any claims.

5.5. Business transfers

Please also note that your information may be transferred to another entity of our group following some internal reorganization or to another third party entity in case of sale, reorganization, restructuring, merger and/or acquisition or any other disposal whatsoever at group or company level resulting that part (more than 50%) or whole of our business (or related assets) is either directly or indirectly transferred or falling under control of a third party acquirer, provided the latter and/or the other group company in case of internal reorganisation operates within same or similar line of business as ours and commits to comply with this Privacy Policy.

5.6. Advertisers/Publishers

If you are an end-user of one of our clients’ websites (Publishers) and interact with the ads, only anonymized data may be shared with the Advertisers or Publishers.

 

6. HOW DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA?

As our clients are part of the EEA, we comply with the EU Data Protection Regulation commonly called “GDPR” (If you want to learn more you can check: EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC), which provides a high level of protection of your personal data.

In case we need to transfer your personal data outside of the European Economic Area, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we will utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

 

7. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

We did our best to explain what your rights are and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, do not worry, our Support Team will provide you with all the assistance you need when exercising your rights.

If you wish to exercise any of your rights below, please send us an email at [email protected].

Our Support Team will provide you with information on actions taken within one month of the day of receipt of your request. Only in exceptional circumstances, when we face complex or a high number of requests, we may extend this period of response up to two further months.

Please note that your rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Please also understand that, because your privacy is so important for us, our Support Team may need to duly verify your identity and ask you to provide additional information before executing your request.

7.1. Data access and data portability

You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge.

Upon verification of your identity, your request will be sent to our Support Team.

If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period of time), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you the information.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). For this purpose, you can send an email to [email protected].

7.2. Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can send an email to [email protected]

7.3. Data retention and erasure

When you are a Publisher or Advertiser, we generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations.

If you no longer want us to use your information, you can request that we erase your personal information.

Your request will be sent to our Support Team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time.

Please note that if you request the erasure of your personal information:

  • We might retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we close or suspend your account for fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information shall also be kept available in case of ongoing judicial proceedings/and or investigations.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
  • Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  • In order to protect our site and your personal information from accidental or malicious loss and destruction, we have backup systems. Residual copies of your personal information may not be removed from our backup systems for a limited period of time.

When you are an end user of our clients sites, please note that we  retain anonymized information only for a maximum of (ninety) 90 days.

7.4. Right to object

We process your data for a variety of reasons as explained in “WHY DO WE PROCESS YOUR PERSONAL DATA?”. Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to the use of your data might disable the use of your account or the use of our clients websites.

Please note that you may, at any time, ask us to stop processing your data for any direct marketing activities.

If you want to exercise your Right to Object, please contact us at [email protected]

7.5. Right to restriction of processing

You have the right to request that we stop processing your data, while we resolve any issues.

Basically, you can ask us to put on hold the use of your data in 4 cases:

  1. If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.
  2. You have objected to a processing activity based on legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.
  3. You consider that the processing is unlawful but you object to erasure and request restriction, instead.
  4. We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

7.6. Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (in particular in the Member State where you live, place of work or of an alleged infringement of the GDPR).

 

8. CHANGES TO OUR PRIVACY POLICY

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the relevant app/site and/or contact you using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force.

Your continued use of our site from that day on will be subject to the new Privacy Policy.

 

9. HOW TO CONTACT US?

If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to [email protected], or to our Data Protection Officer at [email protected], or via mail to the address indicated below, and we will quickly get back to you. We are always glad to talk about our privacy practices.

AdSupply Inc.
10811 Washington Blvd, Culver City
CA 90232, United Sates

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