Privacy Policy

This Privacy Policy (“Privacy Policy”) informs about Personal Data processed through adMarketplace, Inc.’s ("adMarketplace’s") products and services (“Service(s)”), which are provided for the purpose of delivering advertising related services to our Customers.

This Privacy Policy also describes the information collected from this website, www.admarketplace.com, which serves two basic functions. First, it is a portal for information about our Services as well as online advertising generally. Second, it is a portal for adMarketplace publishers and advertisers ("Customer(s)") to access certain restricted, Customer-only materials through a secure log-in.

This Privacy Policy applies when:

1. You visit or interact with our website (https://www.admarketplace.com);
2. You contact us, including through sales inquiries or customer support;
3. You receive marketing or event communications from us;
4. You are a business contact (e.g., employed by one of our customers, partners, or vendors);

This Privacy Policy does not apply to personal data we process strictly on behalf of our customers as a service provider or processor. Where adMarketplace is acting as a processor on behalf of its customers, our obligations with respect to personal data are governed by the applicable agreement between us and our customers, not this Privacy Policy. A separate agreement may govern the provision, access and use of the services ("Agreement"), including the processing of personal data. The company that entered into the Agreement with adMarketplace for the purchase of Services controls its instance of the Services and any associated personal data. Those Agreements also govern Customer business information shared with us (e.g., billing or contact details). In this Privacy Policy, we describe the categories of Personal Data processed through our Services to comply with applicable transparency obligations, even where we act solely as a processor on behalf of our Customers.

This Privacy Policy also does not relate to information shared by employees or other staff, or by applicants for positions with our company. You may reach your business or HR contact for inquiries related to such information.

1. Our Commitment to Data Privacy

adMarketplace is committed to protecting the privacy of consumers, keeping the information we collect secure, and complying with applicable laws. As our practices evolve, this Privacy Policy may be revised to reflect those changes. Notice of such amendments will be posted as an updated policy on this website. Please review this Privacy Policy periodically in order to keep up to date with any modifications.

2. Who is adMarketplace and what is its role under applicable privacy laws?

adMarketplace is a provider of Services that enable our Customers to reach consumers as they search for or indicate intent to learn more about or engage with our Customers’ products or services. Our Services do not use Personal Data to track, target, or otherwise profile consumers across unrelated websites, apps, devices, platforms or properties (collectively referred to herein as ‘Sites’). Personal Data means any information related to an identifiable person and includes IP addresses, cookie identifiers and device identifiers.  

(Personal Data is distinct from Personally Identifiable Information (PII) which is information that on its own is able to identify, contact, or locate an individual. An example of PII is an individual’s email address.  adMarketplace Services do not collect, process, or use PII).

The corporate entity that decides how and for what purpose we process information (the legal basis for processing) is:

adMarketplace, Inc.,
90 Park Avenue,
11th Floor
New York, NY 10016 USA

Email: privacy@admarketplace.com

Certain jurisdictions distinguish between a "controller" or "processor" of personal data. A controller is the decision-maker and exercises overall control over how and why personal data is collected and used. In general, adMarketplace’s Customer is the controller of Customer Data, and adMarketplace is the processor of Personal Data. A processor acts on behalf of, and only on the instructions of, the relevant controller. adMarketplace acts as a controller in limited cases only when it collects or determines the purposes and means of processing Personal Data directly, such as through its own website, marketing activities, business operations, or when using aggregated or de-identified data for service improvement, analytics, or product development. The following words and abbreviations have the meaning provided below:

"Personal Data", "special categories of data", "process/processing", "controller", and "processor" shall have the same meanings given to them in the Regulation (or where the same or similar terms are used under another applicable Data Protection Law, the meanings given to such terms under such Data Protection Law). 

“Data Protection Laws” means any and all privacy, security and data protection laws and regulations that apply to the Personal Data Company has access to under the Agreement, including without limitation (i) the EU General Data Protection Regulation (Regulation 2016/679) (“GDPR”); (ii) the EU e-Privacy Directive (Directive 2002/58/EC); (iii) any national laws made under or pursuant to (i) or (ii); (iv) the Federal Data Protection Act of 19 June 1992 (Switzerland); (v) the United Kingdom Data Protection Act 2018; (vi) the United Kingdom (“UK”) version of the GDPR which is part of United Kingdom law by virtue of the European Union (Withdrawal) Act 2018 (“UK GDPR”); and (vii) U.S. State privacy laws (collectively “State Privacy Laws”) including without limitation California Consumer Privacy Act, Cal. Civ. Code §1798.100, et seq., as amended by the California Privacy Rights Act (collectively, the “CCPA”); the Colorado Privacy Act, C.R.S. §6-1-1301, et seq. and the Connecticut Data Privacy Act CTDPA § 1, et seq.

"Regulation" or “GDPR” means Regulation (EU) 2016/679 of the European Parliament and the Council (General Data Protection Regulation). 

3. Purposes of and Legal Bases for Processing of Personal Data

We process Personal Data as set out below:

a) If you are an internet user visiting one of our Customer’s Sites: On behalf of our Customer, we may process Personal Data in order to deliver ads to the Site you visit.  To illustrate, our technology shows ads in the following ways:

• Pre-search: we show tiles (display ads) for different trusted brands who are our Customers, below the search box
• During search: while a search request is being typed, we may show links that allow you to directly navigate to the brand Site(s) and "skip" having to go to a search engine results page
• Post-search: we may include links to brand Sites within search results
• Native Search: we may include links to brand Sites within editorial, informational or consumer-generated content 
• Push Notifications: if you have expressly opted-in, we may show notifications from brands at a specific time of day to your desktop, mobile or other device
• Auto-complete Search: we may provide auto-complete features and/or redirect your mistyped or misspelled brand searches to the actual brand domain you may have intended to type, and thus bypass parked pages

b) We process Personal Data collected from our Customer’s Sites on their behalf to deliver Services. When you visit a Customer Site that uses our Services, adMarketplace may process Personal Data on behalf of that Customer in order to deliver advertising as described below. The Customer is responsible for determining the legal basis for this processing in accordance with applicable Data Protection Laws, which may include consent or legitimate interests. adMarketplace acts as a processor or service provider in this context and relies on the Customer to ensure the appropriate legal basis has been established. More specifically, our bases for processing when you visit Customer Sites are as follows:

1. For display of advertising, we are a processor or service provider to the Publisher who has legitimate interest or obtained consent from you when you visited their Site, to display advertising
2. When a consumer clicks on an ad (creative) displayed on the site of our publisher customer, we may operate as processor or service provider to the advertiser whose ad (creative) the consumer chose to click and we rely on such advertiser to ensure a lawful basis for processing
3. In order to improve our Services and to develop new services or features for our Customers and understand trends in how users react to particular types of advertisements or offers, once data is no longer reasonably linkable to a particular person or household, we may process it as a controller for our own purposes. Our legal basis for such processing is our legitimate interest in maintaining and evolving our technology and services.
4. In order to maintain security, identify fraud and similar misconduct on the basis of contractual necessity
5. In order to provide insights and reporting back to Customers, such as statistical reporting in connection with the activity on Sites, optimization of the location of ad placement, ad performance, reach and frequency metrics, and billing on the basis of contractual necessity
6. In order to resolve or fix technical issues or problems and to respond to user inquiries and requests on the basis of contractual necessity
7. In order to comply with legal obligation - in some cases, we may have a legal obligation to collect, maintain, or disclose Personal Data about you in relation to the Services as a data controller solely for compliance purposes

c) If you are a visitor to our Site (admarketplace.com), we process certain device-level information as follows for operational purposes including to enable, optimize, and manage the delivery of content. We process this information as a controller based on our legitimate interest in maintaining and improving our website’s functionality. Where required by law, such as under the EU ePrivacy Directive, we will obtain your consent for the use of cookies or similar technologies.

1. To process the information voluntarily shared with us when you contact us (with inquiries, for example) on the basis of consent and/or legitimate interest, and
2. For operational purposes (relating to your device type, for example), to enable, improve, or otherwise manage the delivery of content on our Sites on the basis of consent and/or legitimate interest.

4. What are the Categories of Personal Data we Collect for our Services?

a) Search information such as commercial search terms (keywords) entered into a search box

b) Online Identifiers, including browser and device information such as your device’s Internet protocol (“IP”) address, unique device identifiers such as advertising, hardware or operating system device identifiers (e.g., IDFA for iOS and AAID for Android), information about the type of Internet browser, and general geographic information, and in some cases, cookie IDs. Cookies are text files with a small piece of data sent from a website and stored in a user’s web browser or pixels (graphics embedded in ad content to reflect an interaction with an ad on a Customer’s website – pixels work similarly to cookies). You can find more information about different types of cookies at allaboutcookies.org

c) Commercial Information, including products and services you may have interacted with on the Sites of our Customers

d) Internet Activity, including information about your actions on the Sites of our Customers, such as information related to the Site you are viewing; visit dates and times; the website you came from before, and visited after you clicked on an ad; ad engagement data

e) Advertisement performance information for ads served, viewed, or clicked on, such as information about the type of ad, the online location where the ad was served, whether it was clicked on, and the products and offers viewed  in ads while browsing and searching

f) Inferences drawn by us or our Customers, (or partners of our Customers or who work with us) such as age range, demographics, and product interests, from information collected to segment or predict your preferences and behavior in relation to ad interaction and conversion

g) Purchase Interest, such as interactions on specific Customer Sites that indicate interest in specific products or services, where the Customers have shared this information with us for campaign optimization

As with any information we collect or process, we do not use any Personal Data collected or shared with us to track, target, or otherwise profile consumers across unrelated Sites.

5. What are Categories of Personal Data collected on our website?

a) User Provided Information - on our website’s "contact us" pages, fields are provided so that customers or others interested in our Services can input contact details. We collect this information so that we can respond to the information sent to us

b) Online Identifiers - in order to maintain and manage our website, we record information such as IP addresses, page views and clicks, and cookies for gathering website statistics. This information may be shared with third-party service providers that support our website functionality and analytics, such as, and only to the extent necessary for those services.

6. Statement about Sensitive Information

We do not collect or process any personal information defined as “sensitive personal information” under the CCPA or State Privacy Laws, nor any “special categories of  data” per GDPR. Although we may process inferred commercial or demographics (such as age range) or data not considered sensitive or special category data under applicable laws, we treat all such information as Personal Data and apply appropriate safeguards, especially where it is used for segmentation and audience-based analytics.

All information collected is pseudonymized (other than information provided by customers to adMarketplace in order to receive communications), meaning it does not directly identify an individual but may still relate to one. We treat such pseudonymized information as Personal Data under applicable laws if it can be reasonably linked back to a person or used for ad delivery or measurement purposes.

The Services are not intended to process personal information of children under the age of 16 and we do not knowingly collect, sell, share, or process any personal information from children under the age of 16. If you, as a parent or guardian, believe that your child under the age of 16 has provided their personal data, please contact us and we will use our best efforts to identify and remove their information to the extent it is in our records.

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7. Personal Data disclosures 

When we disclose Personal Data, we disclose it to the following categories of recipients for the following business and commercial purposes:

a) to our Customers or their designated third-party representatives as part of our Services

b) to technology, infrastructure, operations and other service providers to help support the infrastructure necessary to provide the Services

c) to trusted third-party service providers, including our subprocessors, (e.g., web analytics platforms) to support our website functionality

d) We may also disclose information about you:

1. if we are required to do so by law or legal process, including in response to a valid request from law enforcement authorities or other government officials
2. when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity
3. if necessary to protect our legal rights or the legal rights of another individual or entity
4. in connection with a corporate reorganization or a sale or transfer of all or a portion of our business or assets, or
5. to any other person with your consent to the disclosure.

Selling and sharing personal information

We do NOT “sell,” “share,” process or disclose Personal Data for targeted advertising or otherwise as those terms are defined under applicable U.S. Privacy Laws.

8. Security

adMarketplace applies commercially reasonable physical, technical and organizational security measures to protect information from unauthorized access, corruption or loss. These include storing information in databases which are protected by security measures such as password protection, multi-factor authentication, and encryption using Transport Layer Security technology (TLS). However, no system can be completely secure, and we make no guarantees as to security of information transmitted through our Services or our own website (adMarketplace.com). More detailed information about our security for customers is available at https://www.admarketplace.com/data-processing-addendum. 

9. Third Parties we work with

We may use processors or service providers for our business purposes (e.g. for data storage or fraud detection); when we do so, we obligate these services to comply with our Privacy and Security policy requirements and the below Data Privacy Framework for onward data transfers, including obligations to provide the same level of protection that we afford for transferred data.

The adMarketplace website may contain links to third party websites; please be aware that we do not endorse and are not responsible for the privacy practices of those websites. If you follow a link to those websites, you should read their privacy notice and terms and conditions to discern their practices.

10. International Data Transfers

For EU and UK data transfers to entities in countries that have not been deemed to provide an adequate level of protection by the European Commission, we use approved contracts, such as the EU Standard Contractual Clauses for the transfer of personal data to Third Countries pursuant to Regulation (EU) 2016/679 in accordance with Commission Implementing Decision (EU) 2021/914 of 4 June 2021 and the United Kingdom’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses, in force 21 March 2022, as appropriate and additional safeguards where required. 

adMarketplace complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  adMarketplace has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. adMarketplace has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the DPF Principles, adMarketplace commits to resolve complaints about our collection or use of your personal information.  EU, UK, or Swiss individuals with questions concerning our DPF policy may direct them to privacy@admarketplace.com. If we have not been able to satisfactorily resolve the issue, then, you may submit your complaint to JAMS using this link: https://www.jamsadr.com/DPF-Dispute-Resolution. JAMS is the alternative dispute resolution provider designated to address complaints and provide appropriate recourse free of charge to the affected individual.

For transfers of personal data from non-EU/UK countries where international data transfers are limited or restricted, we comply with the relevant applicable laws to legitimize such transfers.

adMarketplace is responsible for processing personal information it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. adMarketplace shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles unless it shows it is not responsible for the event giving rise to the matter.

adMarketplace is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). 

Note: adMarketplace is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to adMarketplace and following the procedures and subject to conditions set forth in Annex I of Principles.

11. Changes to this Privacy Policy

We retain Personal Data for only as long as necessary for the business purpose of the processing. Accordingly, we will delete or return Personal Data processed through our Services upon the documented request of the relevant controller, subject to any legal obligations that require us to retain such data. Aggregated and anonymized data may be retained for a longer period for statistical purposes and for reporting to and billing our customers.

12. Your Privacy Rights under Data Protection Laws

Please note AMP’s Services do not use or rely on PII, such as name, email address and similar data that by itself directly identifies an individual. Rather, we process only limited Personal Data, pseudonymous identifiers such as content IDs or device IDs, to support our Services to controllers as processors. 

If you wish to exercise your rights as outlined below, we may ask you to contact the relevant controller directly, or, where possible, we may request that you identify the controller so that we can transmit your request to them in accordance with our obligations. 

For Personal Data collected via our Services, you should contact the relevant controller (Site publisher or advertiser) that is the business controlling such Personal Data. Accordingly, you may have certain rights regarding your personal information, based on applicable Data Protection Laws, which may include the following:

a) To learn about our processing of your Personal Data – you may request that we provide you: 

1. Confirmation as to whether we are processing your personal information/data
2. The categories of personal information we process about you
3. The purposes of processing, including our business or commercial purpose for collecting, selling, or sharing your personal information
4. The categories of sources from which we collected your personal information
5. The categories of personal information we disclosed for a business purpose and the categories of recipients to whom we disclosed it, especially international recipients
6. The categories of personal information we sold or shared with third parties for targeted or cross context behavioral advertising and the categories of third parties to whom we sold or shared it
7. The existence of any automated processing
8. Expected retention periods

b) To Access your personal information/data portability – You may request that we send you (or another organization, under certain conditions) a copy of your personal data in our possession, in a readily usable and portable format. 

c) To Rectify/Correct inaccurate personal information we may hold about you – You may request that we correct personal information you believe is inaccurate or complete any information you believe is incomplete;

d) To Erase/Delete your personal information – You may request that we delete your personal information under certain conditions or subject to legal exceptions;

e) To Restrict/Limit our processing of your personal information – You may request that we restrict our processing of your personal information, under certain circumstances;

f) To Object to our Processing of your personal information – You may object to our processing of your personal information, under certain circumstances;

g) To Opt-out of certain disclosures of your personal information that may be considered selling or sharing for the purposes of targeted or cross-context behavioral advertising;

h) To Withdraw your Consent – You may request to withdraw your consent for processing that is based on your consent;

i) To Not Be Subject to Discrimination for exercising your rights – We will not discriminate against you for exercising any of your privacy rights by denying you goods or services, charging you or suggesting you may receive different prices or rates for goods or services, or providing you a different level or quality of goods or services if you exercise your rights.

j) To Lodge a Complaint – We appreciate the opportunity to address any complaint you may have about our processing of your personal information or handling of your rights request, so please direct any concerns to us via email at privacy@admarketplace.com.   Regardless, you have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the European Economic Area are available here and for the UK’s ICO here: https://ico.org.uk/global/contact-us/.

In regard to Personal Data collected from our own website (adMarketplace.com), you can withdraw your consent by contacting us. 

13. California Requirements

California residents have certain rights under the California Consumer Privacy Act:
Click here to read additional disclosures required under CCPA.

Shine the Light

California law permits California residents to annually request certain details about how their information is shared with third parties for their direct marketing purposes. We do not share your information with third parties for their direct marketing purposes. 

Changes to this Privacy Policy

adMarketplace reserves the right to change or replace this Privacy Policy at any time to reflect any changes in our privacy practices or updates to applicable laws. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes that affect your personal information if and where this is required by applicable data protection laws. Any changes or replacement will be posted on our website related to this Privacy Policy and located here. We encourage you to review our Privacy Policy on a regular basis. 

Contact Us

For any questions about our privacy practices, you may contact our data protection officer and privacy team via email at privacy@admarketplace.com or by mail at:

adMarketplace, Inc.,
90 Park Avenue,
11th Floor
New York, NY 10016 USA