Privacy Policy

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:

• Browser and Device information, such as the device type and model, manufacturer, operating system type and version (e.g. iOS or Android), web browser type and version (e.g., Chrome or Safari), user-agent, carrier name, time zone, network connection type (e.g., Wi-Fi or cellular), IP address, general location inferred from IP address (e.g. country, region postal or zip code)
• Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether the End User clicked on it, the number of times an End User has seen the ad, and whether the End User visited the Advertiser website or relevant app store and/or purchased or installed the product or service advertised.

Information we receive from Publisher Clients

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:

• Providing Our Services: Generally, we use the information we collect about End Users to provide our products and services (including the Ad Services) as described in this Policy.
• Serving Ads: To allow Publisher Clients to offer advertising inventory in their Digital Properties.
• Ad Reporting and Conversions: To provide information and reports about when and how End Users have been exposed to tads, clicked on ads, or visited their Digital Property.
• Frequency Capping: To prevent End Users from seeing the same ad too many times.
• Performance Analytics: To analyze ad performance, such as tracking views of ads, as well as click-through rates to websites or app stores and/or installs of apps that have been advertised.
• Location-Based Advertising: To deliver location-based advertising, services, and content in real-time through the use of your device’s physical location (where permitted by law).
• Fraud Detection and Prevention and Security: To identify invalid ad impressions, clicks, installs, or ad queries, protect us and our Publisher Clients from fraudulent behavior, and protect the security of the Ad Services.
• Providing, Managing, and Improving our Ad Services and Developing New Services: To facilitate navigation, display information more effectively, and to personalize your experience while using the Ad Services, as well as auditing, researching, and analyzing information to provide, protect, manage, and improve our Ad Services, develop new services, and ensure that our technologies function properly.
• Service Usage and Support: To calculate usage levels of the Ad Services, help diagnose server problems, and administer the Ad Services.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside an End User’s country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside an End User’s country of residence; (d) to enforce our terms and conditions; (e) to protect our operations (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, End Users, or others; and (g) to allow us to establish or exercise our legal rights or defend against legal claims.

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.

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.

Specifically, the information we collect automatically may include IP address, operating system type and version, browser type and version, cookie ID, an individual’s activities on the AdButler Properties, and other information about the individual’s system and connection and how the individual interacts with the AdButler Properties and other websites.  We may collect this information as a part of log files and through the use of cookies or other tracking technologies, as explained further in our Website Cookie Policy.

We may use information collected from the AdButler Properties for the following purposes:

• To send marketing and promotional communications. For example, we and/or our third-party marketing partners may use the information for our marketing purposes (for example, to send promotional emails), in accordance with an individual’s marketing preferences. You may opt out of our marketing at any time (see “Opt Out of AdButler Cookies“).
• To send administrative information. For example, to send information regarding our services and changes to our terms, conditions, and policies.
• To engage in and process transactions. For example, we may use personal information to process your transactions and for billing purposes.
• To post testimonials. We post testimonials on the AdButler Properties that may contain personal information.  Prior to posting a testimonial, we will obtain your consent to use your name and testimonial.  If you wish to update or delete your testimonial, please contact us at hello@adbutler.com and be sure to include your name, testimonial location, and contact information.
• To manage accounts and provide customer support or other services. For example, we may use information to create or administer AdButler accounts and to provide customer support or other requested services or information about the Ad Services.
• To select content and improve quality. We may use information to help improve the AdButler Properties and AdButler Ad Services and to ensure that content on the AdButler Properties is presented in the most effective manner for your device.
• For legal purposes. We may use information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to establish or exercise our legal rights or defend against legal claims.
• For our business purposes. We may use information for our business purposes, such as data analysis, audits, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our products, services, marketing, and client relationships.

We may use cookies and similar tracking technologies on the AdButler Properties to collect and use information about you.  For further information about the types of cookies and other tracking technologies we use, why, and how you can control cookies, please see our Website Cookie Policy.

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:

• To our partners: We may disclose your information to our partners  for the purposes described in this Policy. AdButler., is the party responsible for the management of your personal information jointly used by it and its partners.
• Publisher Clients: If you are an End User, we may disclose information collected through our Ad Services to our Publisher Clients to allow them to analyze the effectiveness and performance of our Ad Services and to offer targeted ad inventory to their advertisers.
• With our vendors, consultants, and other service providers: We may share your information with our third-party service providers, vendors, contractors, or agents who perform functions required for the operation of the business.  Examples include, to provide data storage and processing services, lead management, campaign management, technical support for our Platform and AdButler Properties and fraud prevention.
• Website advertising partners: As noted above, we may partner with certain third parties to collect information on the AdButler Properties to engage in analysis, auditing, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on the AdButler Properties and other websites over time.  We may share information with them for this purpose.
• Business transfers: We may share your information with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or sock (including in connection with any bankruptcy or similar proceedings).
• For legal purposes: We may share your information as we believe to be necessary or appropriate : (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our partners; (f) to protect our rights, privacy, safety or property, and/or that of our partners, you or others; and (g) to allow us to establish or exercise our legal rights or defend against legal claims.
• With consent: We may disclose an individual’s information to any other person with the individual’s consent to such disclosure.
• On message boards or other public webpages: Individuals may choose to share information on message boards, chat, profile pages and blogs and other services that allow visitors to post information and materials (including, without limitation, our Social Media Pages).  Please note that any information posted or disclosed through these services and forums will become public information, and may be available to users of the AdButler Properties and to the general public.  We urge you to be very careful when deciding to disclose your personal information, or any other information, on the AdButler Properties.

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.

Opting out of our sharing of your personal information with partners for their direct marketing purposes

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 team@adbutler.com

Opting out of interest-based advertising from Cookies

To opt out of receiving interest-based advertising (including retargeting) from our Ad Services through the use of cookies in your current browser and for more information on what it means to opt out, please go to Opt Out of AdButler Cookies.

See AdButler’s AdButler Cookie Policy for more information on how AdButler uses cookies and other similar technologies.

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:

1. You may have the right to request access to or that we change, update, or delete your personal information. Please note that we may impose a small fee for access and disclosure of your personal information where permitted under applicable law, which will be communicated to you.
2. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
3. You may have the right to opt out of receiving marketing communications from us. See “Opt Out of AdButler Cookies” for further information.
4. If you are a resident of the European Economic Area (EEA) or the UK, you may also have the following rights:

1. The right to object to processing of your personal information, restrict processing of your personal information, or request portability of your personal information. To exercise these rights please write an email at hello@adbutler.com ; and
2. The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.  Contact details for data protection authorities in the EEA are here and the UK here.

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 hello@adbutler.com. 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.

You should always read the privacy policy of any website you access or social network page through which you share information carefully in order to understand their specific privacy and information usage practices.

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 hello@adbutler.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