Effective May 25, 2018

This Adext Privacy Policy (“Policy”) outlines the information that Adext Corp. (“Adext”, “we”, “us” or “our”) gathers, how we use that information, and the options you have to access, correct, or delete such information.

ADEXT’S PROMISE

Our mission to provide next generation ad tech AI is based in the importance we place on establishing trust with our Customers, Website Visitors, and the Internet community globally. To earn and maintain that trust, we commit to communicating transparently, providing security, and protecting the privacy of data on our systems.

We keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose your personal information to anyone except as necessary to provide our services or as otherwise described in this Policy without first providing you with notice and the opportunity to consent.

1. POLICY APPLICATION:

This Policy applies to Adext’s collection, use, and disclosure of the information of the following categories of individuals:

Attendees:
Individuals who provide their information to Adext or Adext representatives when they attend or register to attend Adext-sponsored events or other events at which Adext participates.

Website Visitors:
Individuals who visit our Websites and who may opt to provide an email address to receive communications from Adext. For the purposes of this Policy, “Websites” shall refer collectively to www.Adext.com as well as any other websites Adext owns and that link to this Policy. For clarity, “Websites” does not include any sites owned or operated by our Customers, including where we serve as Registrar.

Customers:
Those who register on their own or on behalf of an entity or organization to use any of the Adext Services (as defined below), including administrators on a Customer account. For the purposes of this Policy, “Services” shall refer to all advertising service solutions marketed for subscription at www.Adext.com, including when Services are sold by an authorized partner or reseller. 

End Users:
Individuals who visit our Customers’ websites and whose information we process in order to provide the Services to our Customers pursuant to our agreements with them. 

This Policy does not apply to our Customers’ websites, which may have their own terms and privacy policies. Our Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information in connection with the use of our Services by End Users with whom our Customers interact.

Adext’s Websites and Services are not intended for, nor designed to attract, individuals under the age of eighteen. Adext does not knowingly collect personally identifiable information from any person under the age of eighteen.

2. INFORMATION WE COLLECT

Attendees:

We may ask for and collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which Adext (and/or its representatives) participates. 

Website Visitors:

Name, email address, and other contact information. We ask for and—at your option—collect personal information from you when you submit web forms on our Websites, including opportunities to sign up for and agree to receive email communications from us. We also may ask you to submit such personal information if you choose to use interactive features of the Websites, including participation in surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law. Log Files. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Websites, including the Adext Help Forum, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences. Cookies and Other Tracking Technologies. We may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Websites and assisting us in our marketing efforts. You can control how websites use cookies by configuring your browser's privacy settings (please refer to your browser's help function to learn more about cookie controls). Note that if you disable cookies entirely, Adext’s Websites may not function properly. We may also use cookies and similar technologies to provide you advertising on third-party sites based upon your browsing activities and interests. Interactive Areas. The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). If you choose to participate in any of these Interactive Areas, please be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. 

Customers:

Customer Account Information. When you register for an Adext account, we collect your email address and other contact information. We will also ask you to connect to your ad account to use our service. We refer to this information as “Customer Account Information” for the purposes of this Policy. Customer Account Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily providing us with such Customer Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us. Payment Information. You are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information and billing address, although we do not store full credit card numbers or personal account numbers. 

End Users:

Adext provides advertising products and services that our Customers use to improve their advertising campaigns, including management using machine learning (artificial intelligence). It is our Customers and their users who are responsible for the advertising content transmitted across our network (e.g., images, written content, graphics, etc.). 

Legal Basis for Processing (EEA only):

If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the Adext Services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, Adext will not be able to provide the requested service to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.

3. HOW WE USE INFORMATION WE COLLECT

Adext only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of data we collect, we may use the information we collect (including personal information, to the extent applicable) to:

Provide, operate, maintain, improve, and promote the Website and Services; enable you to access and use the Website and Services; process and complete transactions, and send you related information, including purchase confirmations and invoices; send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners.process and deliver contest or sweepstakes entries and rewards; monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; personalize the Websites and Services, including by providing features or content that match your interests and preferences; and process for other purposes for which we obtain your consent. 

Information from Third Party Services. We may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered on an Adext sales submission form with information we receive from a third-party sales intelligence platform vendor to enhance our ability to market our Services to Customers or potential Customers.

4. INFORMATION SHARING

We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us deliver customer support, process credit card payments, manage and contact our existing Customers as well as sales leads, provide marketing support, and otherwise operate and improve our Services. These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations.

Specifically, we do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:

Within the Adext Group (defined for the purposes of this Policy as Adext Corp. (United States);With our resellers and other sales partners who may help us distribute the Services to Customers; With an app developer when you install an app from our App Marketplace; In the event of a merger, sale, change in control, or reorganization of all our part of our business; When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations; or as you may otherwise consent from time to time. 

We do not sell, rent, or share personal information with third parties for their direct marketing purposes, including as defined under California Civil Code Sec. 1798.83.

5. DATA AGGREGATION

Adext may aggregate data we acquire about our Customers and their End Users, including the Log Data described above. For example, we may assemble data to determine how advertising is delivered or to compile web traffic reports and statistics. Non-personally identifiable, aggregated data may be shared with third parties.

6. INTERNATIONAL INFORMATION TRANSFERS

Adext is a U.S.-based, global company. We primarily store your information in the United States. To facilitate our global operations, we may transfer and access such information from around the world, including from other countries in which the Adext Group has operations for the purposes described in this Policy.

Whenever Adext shares personal information originating in the EEA or Switzerland with an Adext entity outside the EEA or Switzerland, it will do so on the basis of the EU standard contractual clauses or the Privacy Shield Frameworks detailed in this section.

If you are accessing or using our Websites or Services or otherwise providing information to us, you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate.

7. DATA SUBJECT RIGHTS

Attendees, Website Visitors, and Customers: You have the right to access, correct, update, export, or delete your personal information. You may email us at [email protected], and we will respond within thirty (30) days. Customers also can access, correct, export, or update their Account Information by editing their profile or organization record at Adext.com.

End Users: Adext has no direct relationship with End Users. Even where “Adext” may be indicated as the authoritative name server for a domain, unless Adext is the owner of that domain, we have no control over a domain’s content. Accordingly, we rely upon our Customers to comply with the underlying legal requirements for subject access requests. If an End User requests that we access, correct, update, or delete their information, or no longer wishes to be contacted by one of our Customers that use our Services, we will direct that End User to contact the Customer website(s) with which they interacted directly. Our Customers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their website users.

For any data change request, we will need to verify a requestor is inquiring about their own information before we can assist. Where a data change request may implicate the personal data of another individual, we must balance the request against the risk of violating another person’s privacy rights. We will comply with data change requests to the extent required by applicable law. In the EU, you also have the right to lodge a complaint with a supervisory authority.

8. COMMUNICATION PREFERENCES

You may manage your receipt of commercial communications by clicking on the “unsubscribe” link located on the bottom of such emails, through your account settings if you have an Adext account.

9. DATA SECURITY, DATA INTEGRITY, AND ACCESS

We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption.

10. NOTIFICATION OF CHANGES

If we make changes to this Policy that we believe materially impact the privacy of your personal data, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Policy on this website noting the effective date of any changes.

11. BUSINESS TRANSACTIONS

We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all our part of our business.

12. ENGLISH LANGUAGE CONTROLS

Non-English translations of this Policy may be provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.

13. CONTACT INFORMATION

Adext Corp.
300 Delaware Ave., Suite 210
Wilmington, DE 19801
Attention: Privacy Protection  

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