Last Updated: July 2023
A reference to “AdButler” “we” or “our” means Sparklit Networks Inc.
AdButler provides ad server technology and solutions via our platform (“Platform”) and related advertising tools (collectively the “Ad Services”). We provide our services and tools to our “Clients,” which include “Publisher Clients” who own and operate websites, mobile applications, and “over-the-top” television devices (“OTT TV Device”), internet connected television (“CTV”) and other online services (each a “Digital Property”) and “Media Buyers” who are advertisers and other ad partners. Our Ad Services help Clients display relevant online advertising to end users (“End Users”) who interact with Digital Properties that use our Ad Services.
AdButler also collects information from individuals when they visit, use, or interact with: (i) www.adbutler.com and other websites operated by us, including AdButler’s client interfaces (the “Websites”); (ii) our software applications (the “Apps”); (iii) our social media pages (our “Social Media Pages”); and (iv) our events, sales and marketing activities.
This Section covers all the information we collect and receive from End Users in connection with our products and services, including End Users of Digital Properties that use our Ad Services.
When End Users visit or use a Digital Property that uses our technology, we (and our partners or vendors) use and deploy tracking technologies to automatically collect certain information about the End Users and their computer or other devices, such as their mobile device, CTV, or OTT TV Device. Some of this information (including, for example, unique identifiers stored in a cookie or your device) may identify a particular computer or device and may be “personal data” in some jurisdictions, including the EU and the State of California.
Our Ad Services are designed to process information in such a manner that the information cannot be directly attributed to a specific, identifiable individual without the use of additional information such as your name, address, or email address, unless you choose to provide that information in connection with any request that you may choose to make directly to AdButler. We (and our partners or vendors) may collect this information when an End User interacts with a Publisher Client’s Digital Property that uses our Ad Services, and we may combine and associate this information (including your Adbutler UID – described below) with other information we (or our partners) may collect about End Users as described in this Policy.
For example, AdButler may assign a unique identifier called an “Adbutler UID” to a browser or other devices. The AdButler UID can be a cookie ID (a unique ID randomly assigned by AdButler to a browser), a mobile advertising ID (a unique ID assigned by the mobile operating system (e.g., Apple ID for Advertising or Android Advertising ID)), or an CTV or OTT TV Device identifier for Advertising (a unique ID assigned by an the OTT or CTV publisher). The AdButler UID enables the Platform to determine within a reasonable level of confidence that a browser or device is the same one with which the Platform has previously interacted...” The other categories of information we automatically collect include:
We may also combine, merge and/or enhance the information we collect about an End User with information collected from our Publisher Clients. For example, our Publisher Clients may also collect information that they choose to pass to us either directly through our Ad Services or through application programming interfaces (APIs), when our Ad Services connect to their systems. This information may include, for example: network type of an End User’s device, age, ethnicity (where permitted by law), gender, and precise geolocation (where permitted by law), mobile device IDs, demographic or interest data, obfuscated user identifiers such as hashed email addresses, and content viewed or actions taken on a website or app to help make the ads served to an End User more relevant while limiting exposure to less relevant ads. Some Publisher Clients may also provide precise geolocation information collected on certain of their Digital Properties. Publisher Clients can create audience segments for their advertising purposes. A segment is a grouping of End Users by one or more attributes (e.g., “cycling enthusiast”). These individuals are identified by an online identifier in these segments but are not identifiable by name or other personal information that directly reveals their identity.
We (or our Publisher clients) may also receive information from third party partners that allows them and/or us to undertake “ID syncing” or “user matching,” which means that in addition to the AdButler UID an End User has been assigned in our systems, we may also receive a list of unique IDs our external partners or Publisher Clients have assigned to the End User, which we match to the End User’s AdButler UID.
We use the information we collect for a variety of business purposes. For example, we use the information we collect for the following purposes:
They help us identify unique browsers or devices used by an End User and to perform functions like, for example, limiting the same ad from continuously reappearing, ensuring that ads are properly displayed on our Publisher Clients’ Digital Properties, and serving an ad more relevant to the End User. To opt out of our use of such technologies for interest-based advertising purposes, please follow the instructions for opting out, as described in “Opt Out of AdButler Cookies” below.
This Section describes how we collect and use information when visitors interact with or use any of the AdButler Properties (such as our Websites).
Certain parts of the AdButler website may ask visitors to provide personal information voluntarily: for example, we may collect personal information when a visitor registers for an AdButler account, expresses an interest in obtaining additional information about AdButler or our products and services, subscribes to our marketing, or otherwise contacts us.
The personal information we collect may include contact information (such as name, address, telephone number, or email address) and contact preferences. It may also include professional information, such as job title, department or job role, and the nature of an individual’s request or communication. We also collect information that visitors choose to provide to us when completing any ‘free text’ boxes in our forms (for example, for event sign-up, product feedback, or survey requests). Please do not post any information that you do not want to reveal to the public at large.
When using the AdButler Properties, we or our third-party partners may automatically collect certain information from an individual’s device. In some countries and states, including countries in the EU and the State of California, this information may be considered personal data under applicable data protection laws.
We may use information collected from the AdButler Properties for the following purposes:
The AdButler Properties are not intended for nor directed to individuals that are deemed to be children under applicable data protection or privacy laws, and we request that such individuals do not provide information through any of the AdButler Properties.
Information we collect may be disclosed:
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving these marketing-related emails by contacting us or by clicking on the opt-out link within the email message that you receive from us. Please also note that if you do opt out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to our services from time to time.
If you would prefer that we do not share your personal information in the future with our partners for their direct marketing purposes, you may opt out of this by contacting us at email@example.com
For more information about cookies in general, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. For more information about how to clear your browser cache, please see your browser’s instructions for doing so.
Some of our Publisher Clients have their own opt-out mechanisms that are linked from their sites or their online-posted privacy policies. You should review the privacy policies of those companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company, or multiple companies.
At this time, we do not honor “Do Not Track” headers and similar mechanisms.
You may have certain data protection rights under laws applicable to you. Those rights may include the following:
Please note that because most of the information we store can only identify a particular browser or device, and cannot directly identify you personally, you will need to provide us with some additional information to enable us to identify the personal information we hold about you and ensure that we accurately fulfill your request and do not infringe on the privacy rights of other individuals.
You can exercise your rights at any time by writing an email to firstname.lastname@example.org. We will respond to your request in accordance with our obligations under applicable privacy laws.
If you are located in the EEA or UK, our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific context in which we collect or use it. We normally rely on our (or our Clients) legitimate interests to collect and use your personal information, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in the sections above with the heading “How Do We Use Your Information”. In connection with our Ad Services, our legitimate interests include the operation of our Platform and the provision of our Ad Services to Clients as required by our agreements with them.
In some cases, we may rely on your consent that we obtain directly from you, or in the context of our Ad Services, which is obtained for us by our Clients that use our technology or use technology that interacts with our Platform. Additionally, we may have a legal obligation to collect data.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contacting Us” heading below.
This Policy does not address, and except as otherwise described in this Policy, we are not responsible for, the privacy, information, or other practices of any third parties, including our vendors or any other third party operating any site or service to which the Ad Services or AdButler Properties link. The inclusion of a link through the Ad Services or Online Property does not imply endorsement of the linked site or service by us or by our partners.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the Ad Services or AdButler Properties.
We use reasonable organizational, technical, administrative, and physical safeguards to protect the personal information we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe and secure. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. 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 has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
We will retain personal information for the period necessary to fulfill the purposes outlined in this Policy and where we have ongoing legitimate business needs to do so (for example, to provide the Ad Services, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations) unless a longer retention period is required or permitted by law.
If you are an End User, we may retain information that we collect through the Ad Services (including the segment information that we receive from third parties) for up to 90 days from the last date that we received any of the End User’s data. We may retain ad impression information for up to 90 days. We may retain raw ad server logs for our CTV and mobile ad server businesses for up to 90 days. We use precise geolocation for the specific ad impression to which the geolocation relates, after which the geolocation information is aggregated with other geolocation data for use by us for analytical purposes. If we de-identify information we collect through the Ad Services, we may retain that information, in an aggregated format, indefinitely. In such cases, we commit to not re-identifying the information. If we are required to retain information to comply with a legal or audit obligation, we may store End User information for longer periods.
In connection with the AdButler Properties and Ad Services, your personal information may be transferred to, and processed by AdButler its service providers and partners in countries other than the country in which you are resident, including in the United States, Canada, India and other locations where we engage service providers or our partners. These countries may have data protection laws that are different from the laws of your country of residence and may not provide the same level of protection as your jurisdiction. Regardless of where your data is located, AdButler shall process your personal information in accordance with this Policy.
We will review and update this Policy periodically and will note the date of its most recent revision at the top of this Policy. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes prior to such changes taking effect, if required by applicable data protection laws. We encourage you to review this Policy frequently to be informed of how AdButler is protecting your information.
If you have any questions about this Policy or AdButler’s privacy practices, please contact us by email at email@example.com, or by mail using the details provided below.
Please note that email communications are not always secure, so please do not include sensitive information in your emails to us.
Sparklit Networks Inc
4110 Shelbourne Ave, Victoria, BC, V8N, 3E7, Canada
Last Updated: July 2023
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