Adcel LLC (“we,” “us,” “our” or “Adcel”) is a mobile advertising company that provides application developers with a platform to deliver more targeted advertising to their consumers. Our technology enables our partners to show mobile application users more relevant advertising that is based on users’ interests and behaviors. In order to provide these services, we collect and use certain information about user activity and preferences.
Adcel participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Adcel is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Adcel is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Adcel complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Adcel is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Adcel may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
This Policy describes the treatment of information provided or collected on or through (i) our U.S. website, which is currently located at www.Adcel.co (the “Site”); (ii) the network of application publishers and developers (the “Adcel Apps”); and (iii) our other online services (together with the Site and the Adcel Apps, the “Services”).
The Policy covers the following topics:
If you have any questions about this Policy or our privacy practices, please do not hesitate to Contact Us.
We collect two main types of information through the Services - personal information and anonymous information and we may also generate a third type of information, aggregate information, as set forth in more detail below. Descriptions of these terms are available in the Definitions section of the Policy.
Please note that we may collect different categories of personal, anonymous and aggregate information from you depending on the nature of your interaction with the Services.
If you are one of our Business Partner, we may collect the following categories of information from you:
If you are a Consumer that downloads and uses an Adcel App or otherwise interacts with the Services, we may collect the device information identified below so that we can provide our services. We may collect and transmit such device information as either raw or hashed data, depending on the sensitivity of the information in question. Adcel does not automatically collect any personal information directly from Consumers but may obtain such personal information from its Business Partners in connection with the Services or when Consumers submit such personal information to Adcel via the Site.
The SDK may collect and transfer non-sensitive device information as raw data, such as:
For additional information regarding the steps we take to safeguard your information, please refer to the Data Security, Integrity and Retention section of the Policy.
Depending on the nature of your interaction with the Services, Adcel may collect information from you automatically and/or when you voluntarily choose to provide us with information. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we collect automatically.
If you are a visitor to the Site or a Business Partner, we collect information that you voluntarily provide us during your interaction with the Services. For example, you may choose to provide Adcel with information when you directly request information or services from us, submit or receive a payment, or complete the online forms available on the Site.
Adcel primarily collects information from Consumers when an application developer or website publisher requests Adcel to serve an advertisement to a consumer. By downloading and using a partner Application, you grant the application developer with permission to collect device information and share it with Adcel. Adcel may track this information over time and across multiple Adcel Apps (and may also combine the device information with anonymous information from other sources) in order to deliver advertisements through the Services. In addition, Adcel may collect information from Consumers through use of a Cookie, Web Beacon, Scripts or similar tracking technologies if the Consumer accesses advertisements from a browser or is redirected to a browser by advertisements provided through the Services. Certain advertisements may redirect you to a browser where Adcel may use a Cookie to track Consumer activities.
Adcel uses the information we collect about you to provide the Services and to gain a better understanding of the products and services that may interest you. For example, we may use your information in order to:
Adcel may process and/or store personal information both within the United States and internationally.
For additional information regarding choices you may have with respect to our use of your information, please refer to the Opt Out section of the Policy.
The Services may link to third party websites, non-Adcel Apps and/or other third party content. Please note that Adcel cannot control the treatment of your information by such third parties, and that the privacy practices of third parties likely differ from those described in the Policy.
Adcel will not share your personal information with other companies, except under the following limited circumstances:
We may disclose your personal information to third parties when you consent to a particular disclosure of your personal information. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.
Adcel may disclose personal information to our trusted agents and service providers so that they can perform requested services on our behalf. For example, we may share payment information with a third party service provider in order to assist us with processing credit card payments. These entities are prohibited from using your personal information for any purposes other than providing Adcel with requested services.
In the event that Adcel is (or substantially all of its assets are) acquired by a third party pursuant to an acquisition, merger, sale, reorganization, liquidation or similar business transfer, the personal information stored in our databases may be one of the transferred assets.
Adcel may share aggregate or anonymous information with Business Partners and other third parties in accordance with the terms of this Policy.
Adcel provides you with the ability to exercise certain choices and controls in connection with our treatment of your information. Depending on your relationship with Adcel, these choices and controls may include:
If you would like additional information about the choices and controls that may be available to you, or you would like to access your personal information, please contact us. We will respond within a reasonable time.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to email@example.com
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to firstname.lastname@example.org
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
We do not use the Services to knowingly solicit data from or market to children under the age of thirteen (13). We request that such individuals do not provide personal information through the Services. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.
If a partner flags their application or mobile website as directed towards children under 13, we will not collect any information on these users for behavioral marketing, profile building, or remarketing purposes.
Your privacy is very important to Adcel and we are committed to protecting your personal information from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft.
In addition, we take steps to ensure that information is stored in an anonymous format through a technique known as “hashing”. When a Consumer downloads and uses an App or website that requests Adcel to serve advertisements, we may collect and process information locally on the Consumer’s mobile device. This allows us to identify the sensitivity level of certain device information prior to transferring it to our servers for storage. Rather than sending sensitive device information as raw data that can be easily associated with the relevant Consumer, we only transfers anonymous hashed representations of certain types of information back to Adcel. Our servers then associate the hashed representations with a unique anonymous identifier assigned to each Consumer by Adcel. When a Consumer subsequently interacts with the Services, this process allows us targeted advertising without storing any sensitive information in a form that would be easily readable to unauthorized third parties.
Adcel also protects Consumer privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. For additional information regarding how we store data, please refer to the Consumer Privacy portion of the Site. You may also contact us anytime with your questions or concerns.
Adcel retains the raw data it collects from Consumers for up to 2 years. The information received from Business Partners is retained for as long as needed to provide you services. We will retain and use the information we receive for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We may, in our sole discretion, make changes to the Policy from time to time in order to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The most recent version of the Policy will always be posted on the Site. If we do make any changes, we will also update the “Effective Date” posted at the top of the Policy. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to review the Policy periodically to ensure that you understand how we collect, use and share information through the Services.
Any changes to the Policy will become effective when the revised Policy is posted on the Site. By continuing to use the Services following such changes, you are agreeing to accept the terms of the revised Policy.
Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.
Aggregate information refers to de-identified information about groups or particular types of individuals that use the Services. Such information does not identify you as a particular individual. An example of aggregate information would include the total number people that accessed an Adcel App from a particular region or while using a specific type of mobile device.
Anonymous information refers to information that does not (and cannot reasonably be used to) directly or indirectly identify you as an individual, such as the IDFA and/or IP Address of the device that you use to access the Services. If anonymous information is ever directly or indirectly associated with personal information, Adcel will also treat the combination of data as personal information.
Adcel Apps means the mobile applications within our network of application publishers and developers.
Business Partners are the mobile application advertisers, publishers and developers in the Adcel network that have registered for the Services.
Consumers are those individuals who download, use or otherwise interact with an Adcel App.
Device information refers to the information automatically collected from a Consumer’s device by our SDK. Such information may be processed locally, or transferred to Adcel for processing and/or storage. Adcel may collect and/or store device information as raw or hashed data. For a complete list of the device information we collect from Consumers, please refer to the Information We Collect From Consumers section of the Policy.
Hashing is a technique that anonymizes data. Storing information as hashed data allows Adcel to associate certain information with a Consumer without directly affiliating him or her with personal information. Adcel stores sensitive information in hashed form to help protect the privacy of such Consumers while providing the Services. Please refer to the Data Security, Integrity and Retention of the Policy or the Consumer Privacy portion of the Site for additional information about how we use “hashing” to safeguard Consumer information.
Personal information means information that can be used, either directly or indirectly, to contact you or identify you as a particular individual.
Raw data refers to data that has not been processed for a particular use or otherwise transferred from its original format. Adcel only stores non-sensitive device information as raw data.
Software Development Kit (SDK).
Adcel’s SDK, which is integrated into each Adcel App, is software that allows our Business Partners to provide you with social and personalized content. By downloading and using an Adcel App, Consumers grant the application developer with permission to collect such device information and share it with Adcel. Adcel may track this information over time and across multiple Adcel Apps (and may also combine the device information with anonymous information from other sources) in order to deliver targeted advertisements through the Services.
A web beacon (sometimes referred to as a “pixel tag” or a “clear GIFs”) is a programming code that can be used to display an image on a website, email or other communication. Web beacons are typically one-pixel, transparent images and are used to transfer an individual’s unique user identification (often in the form of a cookie) to a database in order to associate that individual with previously acquired information about him or her in a database. Adcel uses web beacons keep track of certain online behavior (e.g., the websites you visit, the mobile applications you use, your interaction with Adcel emails etc.) in order to help us to determine the types of things that you find the most interesting.