Effective Date: September 24, 2024

1. Introduction

2. About Our Services

3. Scope

4. What Information We Collect

5. Use of Cookies and other Tracking Technologies on Our Site

6. Why We Collect Information

7. When We Disclose Information

8. Retention of Personal Information

9. Your Choices About the Information We Collect

10. Children’s Privacy

11. Visitors to the Site Outside of the United States

12. Links

13. Security

14. Your California Privacy Rights

15. Your Privacy Rights under Other US State Laws

16. Information for EEA and UK individuals

17. Changes to This Privacy Notice

18. Contact Us

1. Introduction

Welcome. You have arrived at a website provided by Aditude, Inc. and its subsidiaries  (“Aditude,” “we,” “our” or “us”). Aditude is a team of adtech innovators obsessed with helping publishers. We love to help them grow and thrive. And we're very, very good at it. We’ve been in adtech since the beginning, and nobody knows ad operations like we do. From pioneering the first header bidding integration before prebid was a thing, to managing ad ops for the largest publishers on the planet, we’ve done it all. At Aditude, we take your privacy seriously. We provide this Privacy Notice (“Notice”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information. If you have questions about this Notice after you review it, feel free to contact us at privacy@aditude.io.

2. About Our Services

We provide technology that connects buyers of advertising inventory (“Advertisers”) with sellers of advertising inventory (“Publishers”). In other words, we provide Advertisers with the opportunity to display their advertisements across Publishers’ websites and applications (collectively, “Digital Media Assets”). In this Notice, we refer to Advertisers and Publishers collectively as “Clients.”

When an Advertiser serves an advertisement on a Publisher’s Digital Media Asset, the advertisement will be displayed to consumers (“Consumers”) in connection with the content that they view. For example, if a Consumer visits a video-streaming Digital Media Asset and clicks on a video to stream, then an advertisement may appear before the video is shown because the Advertiser successfully purchased the opportunity to display an advertisement before that video.

3. Scope

We collect certain kinds of Personal Information from Consumers, current and potential Clients, visitors to our Site (“Site Visitors”) and individuals applying for employment with us (“Employment Applicants”). For the purpose of this Notice, "Personal Information" means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. The definition of Personal Information does not include publicly available information from federal, state, or local government records, such as professional licenses and real estate or property records.

This Notice applies to our collection of Personal Information through the following channels:

• Our website, aditude.com, its subdomains, all subdomains or portals that link to this Notice, and any and all branded root domains owned by us now or in the future (“Site”); 

• Online through emails, texts, phone calls or other communications with our representatives or in any other instance when you contact us;

• In-person at events;

• Our social media accounts; 

• The Careers section on our Site or online employment portals; and

• Our Clients’ Digital Media Assets, such as when you visit their website or use their applications. 

We refer to all the above as our “Services.” This Notice does not apply to the collection, use and disclosure of Personal Information by our Clients through their Digital Media Assets, which is governed by their own privacy policies and practices. 

4. What Information We Collect

We collect Personal Information in a variety of ways:

• From Clients giving us information so that we can help them monetize advertisement inventory space on their Digital Media Assets;

• Using cookies, pixels or other tracking technologies;

• From Clients uploading data onto our platform;

• From Clients and partners using our technology to gather data; and

• Through the process of serving advertisements

As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you.

A. Information That You Provide to Us

As you interact with our Site or Services, we collect the following Personal Information via webforms or inputs/uploads on our Site, and through telephone calls, letters, emails and other communications with you.

Site Visitors

• Contact information such as your first and last name, email address, telephone numbers, mobile numbers and information about your website.

Clients

• Contact information such as your first and last name, job title, email address, business address, telephone numbers, mobile numbers; and

• Financial information such as your business credit card or debit card number, bank account information and your payment, service and purchase history.

Consumers

• We have limited interaction with consumers and generally only collect their Personal Information according to the Information That Is Automatically Collected section below.

Employment Applicants

• Contact information such as your first and last name, email address, home or business address, telephone numbers, mobile numbers;

• Your current or past employment or educational information;

• Relevant licenses and certifications; and/or

• Other information that could help us determine if you’re a good fit for us and that could reasonably be used to identify you.

B. Information That Is Automatically Collected from Our Site

Like many businesses, we and our service providers automatically collect and/or store certain Personal Information from Clients, Site Visitors and Employment Applicants when they visit the Site or interact with our Services. 

Specifically, we collect via cookies and other tracking technologies the following “Usage Information,” which may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”):

• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;

• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);

• Referring and exit web pages and URLs; 

• Web browsing history from advertising impressions;

• The areas within the Site that you visit and your activities there;

• Your Device location or other location information, including the zip code, state or country from which you accessed the Services;

• Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware); 

• Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;

• Information about your engagement with our emails; and

• Statistical information about how both unregistered and registered users, collectively, use the Site and Services.

For location information, some of our Services include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). If you use Location-Based Services, we collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used. 

If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

Additionally, we provide Audience Analytics Services. Through this service we collect Personal Information to understand our audience through statistics.

C. Information That Is Collected from Our Digital Media Assets

As a part of our business model, we also collect Personal Information from Consumers when they interact with our Clients’ Digital Media Assets.

Specifically, we collect via cookies and other tracking technologies the following Usage Information, which may be stored and/or accessed from your Device:

• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;

• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);

• Referring and exit web pages and URLs; 

• Web browsing history from advertising impressions;

• The areas within the Digital Media Assets that you visit and your activities there;

• Your Device location or other location information, including the zip code, state or country from which you accessed the Services;

• Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware); 

• Certain other Device data, including the time of day you visit our Digital Media Assets or other information used to provide analytics or other usage information;

• Information about your engagement with our emails; 

• Information about your behavior on Digital Media Assets; and

• Statistical information about how both unregistered and registered users, collectively, use the Digital Media Assets.

D. Information Collected from Third Parties

Related to Our Site and Services: In addition, our Site includes functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Aditude from third parties. We might also provide links to make it easier to send a communication from the Site, or we may use third parties to make it easier to send emails or post to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Aditude. We do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Related to Digital Media Assets: As a part of our business, we collect from our Clients the following pseudonymous Personal Information about Consumers:

• Location data

• Information described in the Information That Is Automatically Collected section above)

• ID syncing data

5. Use of Cookies and other Tracking Technologies on Our Site

We use various methods and technologies on our Site to store or collect Usage Information (“Tracking Technologies”). (For information about how our Clients use Tracking Technologies on their own sites, please visit their privacy policies). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

• Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage. 

• Pixels: A pixel is a small graphic file that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site

• Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and our services and messages.

• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. 

• Browser Extensions. This technology may capture Personal Information, such as email addresses, if an individual visits our Site while logged in to a web browser such as Google Chrome. It may also capture actions, taken in the Extension UI, related to the user’s email.

• ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. 

• Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

• Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user). 

We may use the following types of cookies:

• Strictly necessary cookies. These cookies are essential for you to browse the Sites and use its features, such as accessing secure areas of the site. 

• Functionality cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your user name and password are so you can automatically log in.

• Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services if the cookies are for the exclusive use of the owner of the website visited.

• Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.

6. Why We Collect Information

We use the information we collect about you in a variety of ways, including the following:

A. Related to Our Site and Services 

To Provide Our Services

We process certain Personal Information when you access or use Site or Services, including to:

• create and verify user accounts;

• facilitate the functionality of our Site and

• customize experiences and personalization when you are on our Site.

To Communicate with You

We process certain information to communicate with you in relation to Client accounts, our services, our marketing, and your requests, including to:

• communicate with you about orders, purchases, services, accounts and programs;

• respond to your customer service inquiries and requests for information;

• post your comments or statements on our Site;

• send you personalized promotions, content, and special offers;

• communicate with you about our Services, products, events, or other promotional purposes;

• implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and

• provide important product safety information.

For Improvement of Our Site or Services

We want to ensure that our Site and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

• maintain, improve, and analyze our Site or Services; and

• detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

• maintain appropriate records for internal administrative purposes; and

• comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

To Evaluate Your Application for Employment

We use your Personal Information to evaluate your application for employment or administer employment benefits.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

B. Related to Digital Media Assets

To Provide Our Services

We process certain Personal Information when you access one of our Clients’ Digital Media Assets, including to:

• deliver and personalize advertisements;

• limit the number of times you see an advertisement;

• create and verify user accounts;

• associate devices or identifiers that may be related to each other;

• maintain records;

• facilitate the functionality of our ads on the Digital Media Asset; 

• associate devices or identifiers that may be related to each other;

• prevent malicious or fraudulent activity;

• improve advertisements on Digital Media Assets; and

• customize experiences and personalization when you are on the Digital Media Assets.

• create and use profiles for advertising purposes 

7. When We Disclose Information

To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations related to our Site or Services as well as our Clients’ Digital Media Assets:

• Service providers. To provide information to our affiliates and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. 

• Marketing and advertising partners. With respect to our Sites or Services, and excluding our Clients’ Digital Media Assets, we also may share your information, including your Personal Information, with our affiliates and other third parties, such as media buyers and other companies with whom we have marketing or other relationships. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Notice. 

• Legal process. To comply with a validly issued and enforceable subpoena or summons; as a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record. 

• Business transactions. In conjunction with a prospective purchase, sale, or merger of all or part of our practice, if we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.

Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Site or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

8. Retention of Personal Information

Aditude will retain your Personal Information only for as long as is necessary for the purposes set out in this Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

• Event-level / user-level data - We may retain event-level and/or user-level data for (i) up to 390 days; (ii) as otherwise required by law; or (iii) as long as is necessary for the purposes set out in this Notice

• Aggregated data - We may retain aggregated data, and non-Personal Information in perpetuity.

• Cookies - Cookies can expire up to 390 days from the time the cookie is stored in the user's browser or device, if activity is refreshed by the user, this can reset the expiration date (curious if this is compliant)

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

• How long we have had a relationship with you or provided our Services to you

• The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

• Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;

• The privacy impact on individuals of ongoing retention; and

• The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

9. Your Choices About the Information We Collect

A. Communications Preferences

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). 

You can opt out of receiving marketing emails from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Notice.

B. Controlling Your Cookies 

You can opt-out of cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Sites’ cookie preference centers.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:

• Apple Safari

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

Note that if you turn cookies off, you may be unable to access certain parts or benefit from the full functionality of the Sites. To learn more about cookies and similar technologies or to opt-out of targeted advertising cookies, visit resources from the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs. 

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. 

C. Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

10. Children’s Privacy

Our Site is not intended for use by children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are the parent or guardian of a child under 18 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

11. Visitors to the Site Outside of the United States

All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Notice.

12. Links

For your convenience, the Site and this Notice may contain links to other websites. Aditude is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Aditude endorses or has any affiliation with the links.

13. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk. 

14. Your California Privacy Rights

This section of the Notice applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

• To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;

• To know the length of time we intend to retain each category of Personal Information; 

• To know whether your Personal Information is sold or disclosed and to whom;

• To access your Personal Information;

• To delete the Personal Information you have provided to us, with certain exceptions; 

• To correct your Personal Information;

• To opt out of the sale of Personal Information; 

• To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared; 

• To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and

• Not to be discriminated against, even if you exercise your privacy rights.

A. Request for Information, Correction, or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

• The categories of Personal Information collected about you;

• The categories of sources from which the Personal Information is collected; 

• The business or commercial purpose for collecting, selling or sharing Personal Information;

• The categories of third parties to whom the business discloses Personal Information; and

• The specific pieces of Personal Information collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information. 

B. Personal Information Collected 

We have collected the following categories of Personal Information from consumers within the last twelve (12) months. Please note that some categories might not apply to some individuals. Please see the “What Information We Collect” section above for more information.

Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above. 

C. Personal Information Sold or Shared

We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

D. Personal Information Disclosed for Business Purposes

We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:

E. Do Not Sell My Personal Information

Related to our Site: As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.”  If you wish to opt out of the aforementioned, you may submit a request to opt-out by emailing us at privacy@aditude.com.

Related to Digital Media Assets: If you are a Consumer who has reached a Digital Media Asset of one of our Clients, please contact that Client to opt out of the sale of Personal Information and targeted advertising.

F. Right to Limit Use of Sensitive Personal Information

California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Currently, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you. 

G. Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

H. Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes. 

I. Exercising Your California Privacy Rights 

You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by emailing us at privacy@aditude.com.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

15. Your Privacy Rights under Other US State Laws

Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

• To confirm whether or not a controller is processing your Personal Information and to access such Personal Information; 

• To correct inaccuracies in your Personal Information; 

• To delete your Personal Information; 

• To obtain a copy of your Personal Information that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means; 

• To opt out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. 

• Not to discriminate against you because you have exercised any of these rights, including by:

• denying you Services;

• charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;

• providing you a different level or quality of Services; and/or

• suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your Personal Information for targeting advertising, sale, or profiling by contacting us by email at privacy@aditude.com using the information in the Contact Us section below.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period. 

A. Right to Opt Out 

Related to our Site: You may have the right to opt out of the sale of Personal Information and targeted advertising. To exercise your right, you may submit a request to opt-out by emailing us at privacy@aditude.com. If you are a Consumer of one of our Clients, please contact that Client to opt out of the sale of Personal Information and targeted advertising.

Related to Digital Media Assets: If you are a Consumer who has reached a Digital Media Asset of one of our Clients, please contact that Client to opt out of the sale of Personal Information and targeted advertising.

B. Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

C. Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. 

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

16. Information for EEA and UK individuals

This section of the Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”) or the United Kingdom (“UK”). This section provides you with additional information, including about the rights that you have, which we are required to provide to you to comply with European privacy laws, including the European Union’s General Data Protection Regulation and the UK GDPR (collectively such European laws being referred to as the “GDPR”). 

For the purposes of the GDPR, we are a controller for data collected on our Site; and are a processor for our Clients for other data that we process about Consumers. If you are a Consumer who has reached a Digital Media Asset of one of our Clients, please contact that Client if you would like to opt out of the sale of Personal Information and targeted advertising.

A. Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

• Contract: To conclude or perform a contract with you; for example:

• To provide our Services;

• To manage our accounts and records;

• To handle your inquiries and requests;

• When you apply for employment through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.

• Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:

• To respond to your customer service inquiries and requests for information;

• To maintain, improve, and analyze our Site, ads, and Services we offer;

• To conduct marketing activities;

• To detect, prevent, or investigate security breaches or fraud; and

• To facilitate the functionality of our Site;

• Legal Compliance: To comply with our legal obligations; for example:

• To maintain appropriate records for internal administrative purposes and as required by applicable law, and

• Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

B. Your Rights Under the GDPR

IWe want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information.

Under the GDPR, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have collected from you. 

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Information.

• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

• The right to data portability. You have the right, in certain circumstances, to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent. You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

If you would like to exercise these rights you can do so by submitting a request to us using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. Please include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request.. 

Please note that we will ask you to verify your identity and/or legal standing to make the request (including your entitlement to make the request on behalf of another person and your residency in the EEA or UK) before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), we would welcome the opportunity to address these concerns – please contact us using the contact details below. However, you are also entitled to report any concerns that you have to your local supervisory authority. A list of supervisory authorities can be found here. If you are in the UK, contact details for your supervisory authority, the Information Commissioner’s Office, can be found here.

Email: privacy@aditude.io 

C. Our transfers of Personal Information outside the EEA/UK

We are located in the USA. Therefore, your Personal Information may be processed by us in the USA for the purposes set out in this Notice.

We may also transfer Personal Information to third parties that do not protect Personal Information to the same standard as the GDPR. These countries may not give you the same rights in relation to your Personal Information and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your Personal Information. 

When transferring Personal Information, we will ensure, where required by the GDPR, that one of the following applies:

• Adequacy Decisions: We will only transfer your Personal Information to countries or organisations that have been deemed to provide an adequate level of protection for Personal Information by the European Commission, the UK Government, or any other relevant governmental body.

• Contractual Safeguards: We may use specific contracts approved by the European Commission, the UK Government, or any other relevant governmental body, to safeguard Personal Information. The contracts that we usually rely on are referred to as “Standard Contractual Clauses” or “SSCs”, although we may from time to time use other approved mechanisms. To find out more about the SCCs we use, please see here (EU) and here (UK). You can also contact us using the contact details set out above.

17. Changes to This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Notice on this page and will indicate at the top of the page the modified Notice’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy Notice. If required by the applicable law, we will notify you of the changes. 

By continuing to use the Site or Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be bound by the Privacy Notice as changed.

18. Contact Us

If you have any questions or suggestions regarding this Notice, please contact us as follows:

Aditude, Inc.
8 The Green #13369
Dover, DE
19901
privacy@aditude.com