Last Updated: October 2, 2017

 

Adelphic LLC (“Adelphic”) is a mobile and cross-channel programmatic advertising platform that helps brands meaningfully connect and engage with the right audiences.

This Privacy Policy describes Adelphic’s practices and policies for information we collect through our website located at www.adelphic.com (the “Site”) and through Adelphic’s advertising platform (the “Adelphic Service”). The Adelphic Service is designed to deliver, target and report on advertising messages delivered onto computers, mobile phones and similar devices. Those ads are delivered to those who use those devices (the “Users”).

By partnering with us as a publisher, advertising through the Adelphic Service, or visiting the Site and/or otherwise using the Adelphic Service, you agree to the terms of this Privacy Policy.

Information We Collect

Personal Information That You Give Us

We generally do not collect or use personal information about individual Users through the Adelphic Service. When we say “personal information,” we mean individually identifiable information that would allow us to determine the actual identity of and/or directly contact a specific living person, such as an email address or telephone number.

We collect personal information only when we are contacted directly by an individual through the Site and the individual voluntarily provides personal information to us, such as by submitting a question or registering to use the Adelphic Service. Adelphic does not collect personal information about consumers that receive advertiser offers through the Adelphic Service.

To the extent we receive it, we use personal information only in ways compatible with the purpose for which it was collected, such as to respond to such communications, to complete registration for the Adelphic Service, or to use the Adelphic Service. We take reasonable steps to ensure that any personal information is relevant to and reliable for its intended use. By voluntarily providing us with personal information, you are consenting to our use of it in accordance with this Privacy Policy.

Information We Collect Automatically

The Adelphic Services collect information about your device and the ads that we deliver onto your device. This data, which is collected passively using various technologies may come from such sources as your web browser or the apps that you use. We also may obtain the precise location (e.g., lat/long coordinates) of your device and may use that information to target ads. We also combine the information collected across multiple sites and mobile apps in order to create interest segments that help us target future advertisements based upon those inferred interests. This practice is sometimes referred to as behavioral advertising or interest-based advertising. We use this information as part of the Adelphic Services to perform a variety of tasks, such as limiting the number of times a specific advertisement is presented to the same User (frequency capping), providing an advertisement to only certain types of Users, or providing a report to a client on the number of its advertisements that were clicked. We may share this information with clients, vendors, and other companies that we conduct business with as permitted by law.

Cookies and Similar Technology

In operating the Adelphic Service and Site, we may use a technology called “cookies,” which are small text files that our Site serve to your browser when you access the Site. Our cookies may collect and store audience segments, help provide additional functionality to the Adelphic Service and Site, and help us analyze usage more accurately.

We may also use an advertising identifier created by your mobile operating system to store information on our servers and later retrieve it to provide the Adelphic Services. The Android Advertising ID and Apple iOS’ IDFA are examples of advertising identifiers. For more information about advertising identifiers, please check the settings of your mobile device. The advertising identifiers provide similar functionality as cookies when used to provide the Adelphic Services.

How We Use Information We Collect

Personal Information

Adelphic may use personal information as follows:

– to fulfill your requests, such as to create an Adelphic Service account or respond to a sales inquiry;

– to send you important information regarding the Adelphic Service and Site and your use of the Adelphic Service and Site, including changes to terms, conditions and policies;

– to inform you of products, programs, services and promotions from us and/or our marketing partners that we believe may be of interest to you, and;

– for our internal business purposes, such as data analysis, audits, developing new products, enhancing the Adelphic Service and Site, improving our services, and identifying usage trends

Pseudonymous Ad Serving Information

Adelphic uses the pseudonymous information we collect via the Adelphic Service to create audience segments that make advertising delivered to consumers more relevant. This process is sometimes referred to as interest-based advertising. This information is typically associated with the advertising identifier referenced above. This information is used by us, our clients and partners, including advertisers and publishers, to deliver targeted advertising. In the process of serving an advertisement to a device, we, or our partners, may decide to serve an ad based on one or more audience segments associated with that device, and the audience segment we believe may be associated with that device. Where Adelphic is able to use this and other information to infer that one browser or device likely belongs to the same User or household, the Adelphic Services may consider those browsers and devices “linked” for purposes of ad serving and interest based advertising This linking process is sometimes referred to as creating a device graph. The data we collect is also used for reporting purposes, to give our clients more information about the performance of their advertising campaigns, and to improve performance over time.

Your Choices – Opt Out Process

If you want to opt out from interest based advertising from Adelphic, click here.

You may also opt-out of interest-based advertising from many of Adelphic’s partners at the DAA’s opt-out site.

Access/Correction

Adelphic generally does not collect personal information through the Adelphic Service, and only via the Site when it is provided to us. In most cases, if and/or when we obtain personal information, it relates to our current or prospective clients and business partners. You have certain access rights to your personal information contained in our systems. If you have submitted personal information through the Adelphic Service or Site and wish to access, correct, or delete this personal information, please contact us at info@adelphic.com.

 

Children

We do not knowingly target advertisements to children under the age of thirteen (13) nor do we knowingly collect any personal information from children under the age of 13.

Information Sharing

With our Clients and Business Partners. The Adelphic Service is used by advertisers, publishers and other companies providing advertising services such as advertising agencies. We may share audience segments with these clients to enable them to deliver targeted advertising and to conduct analytics. Where we share information with such third parties, we require them to follow privacy and data security principles and practices that are substantially similar to ours. When you opt-out of our services (as described above), we stop sharing interest based advertising data with these third parties.

With our Service Providers and Vendors. We may employ other companies and individuals to perform services and functions on our behalf.

Adelphic may otherwise share any information it collects:

– if Adelphic believes that doing so is legally required;

– to protect against harm to the rights, property, or safety of Adelphic, our partners, or the public as required or permitted by law;

– if Adelphic is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, as permitted by law and/or contract. Adelphic may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Onward Transfer

We are a growing corporation with operations in multiple countries. We have developed data practices designed to assure information is appropriately protected. While our primary data centers are in the United States, we may transfer personal information or other information to or from Adelphic offices outside of the United States. If we disclose personal information to a third party or to Adelphic employees outside of the United States, we require assurances that any information we may provide to them is safeguarded adequately and in accordance with this privacy policy and the requirements of applicable law. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Principles, respectively, Adelphic is potentially liable.

Information Security

Adelphic is committed to protecting the security of the information we collect. We use a variety of technologies and procedures to protect information from unauthorized access, use or disclosure. However, no digital transmission or form of electronic storage is ever fully secure or error free. Therefore, we cannot guarantee its absolute security. Please keep this in mind when disclosing any personal information to Adelphic.

Data Retention

We store personal information such as email address, telephone number or billing details for so long as you continue to have a business relationship with Adelphic and for a reasonable time thereafter for record keeping purposes. You may ask us to delete that information by following the instructions below. We store pseudonymous identifiers such as cookie IDs and mobile advertising ID’s collected via our Services for as long as our systems are able to recognize a particular User and for 90 days thereafter. The pseudonymous ad serving and targeting data that is generally associated with those pseudonymous identifiers is stored on a 90-day rolling basis.

Data Integrity, Purpose Limitation

We process information in a way that is compatible with and relevant for the purpose for which it was collected as described above. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

Recourse, Privacy Complaints by European Union and Swiss Residents

 

Adelphic complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Adelphic has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Adelphic commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Adelphic at: privacy@adelphic.com.

Adelphic has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

DAA Principles

Adelphic is a member of the Digital Advertising Alliance (DAA) and complies with DAA’s Self-Regulatory Program for Online Behavioral Advertising.

Changes to the Adelphic Privacy Policy

Adelphic will maintain personal information in accordance with this privacy policy. If Adelphic decides to change this privacy policy, we will post the changes on this page and revise the “Last Updated” date above. Any changes to our Privacy Policy will become effective upon our posting of the revised Privacy Policy on this page. Use of the Adelphic Service or Site following such changes constitutes your acceptance of the revised Privacy Policy that is in effect.

Contact Information

For questions or concerns relating to privacy, please contact us at info@adelphic.com.