Privacy Policy

Updated on: May 15, 2023

Welcome to AIDEM Privacy Policy. We are committed to protecting your privacy and treating your personal information with transparency, care, and respect.

This Privacy Policy (Policy) explains how we collect, use, and share (collectively, Access) your personal information, personal data, or the equivalent terminology in your region (collectively, Data). For reference, Data refers to any information that may directly or indirectly identify you. The Policy also explains how you can exercise your rights under applicable data protection and privacy laws, including data protection and privacy laws in California, Europe, and Brazil.

Any reference in this Policy to AIDEM, we, or our means AIDEM Technologies LTD, and its direct and indirect global subsidiaries.

1. About AIDEM

AIDEM is a global digital advertising marketplace. Our technology (the AIDEM Platform) helps our clients deliver advertising to you. The AIDEM Platform hosts digital auctions that help our clients buy and sell online ads (collectively, our Platform Services). These ads can be found on websites, mobile applications (apps), or video programming services, such as streaming apps on Smart TVs (collectively, Digital Properties).

As with any exchange platform, we act as both as an intermediary between buyers and sellers, and as a buyer. Throughout this Policy, we refer to our clients that sell ad space as Publishers. Publishers own or operate the Digital Properties you may use or visit. We refer to clients that buy ad space (e.g., advertisers) as Buyers. Buyers may include Demand-Side Platforms (DSP) and other partners (collectively, Demand-Side Partners). Demand-Side Partners act as additional intermediaries in the digital advertising supply chain that connect advertisers to AIDEM to serve relevant ads to you on the Publisher Digital Properties you visit. Demand-Side Partners liaise with other Buyers, which also include advertisers (e.g., brands), and advertising agencies (collectively, Ad Partners). In summary, AIDEM and Demand-Side Partners act as intermediaries that connect Ad Partners with Publishers to deliver relevant digital ads to you.

This Policy describes AIDEM’s Data practices. It does not apply to information or Data collected by third parties, including those of Publishers or Buyers. We recommend that you consult the privacy policies of the Digital Properties you use in order to become familiar with their privacy practices.

Please note, Sections 1-10 of this Policy provide information about the Data we Access in the provision of our Platform Services to our clients. For information on our corporate Data collection practices, please refer to Section 11 Corporate Privacy Policy.

We recommend that you read this Policy in full; however, the links on the right are intended to help you navigate to sections that are relevant to the information in which you may be interested.

2. How we access your data

AIDEM may Access your Data in different ways depending on the way you interact with us. Please find below an overview of how we may Access your Data.

Platform Services: AIDEM Accesses your Data when you visit a Publisher’s Digital Properties. AIDEM Accesses your Data only to provide our Platform Services if we have permission from Publishers to do so. The Data we Access is limited to digital identifiers specified in Section 3 Types of data we access (e.g., device information, IP address).

Corporate: If you interact with us in a business capacity, we Access your Data as part of our business relationship with you, either pursuant to a written agreement, or because of our legitimate interest. Please refer to our Corporate Privacy Policy for more information.

Website: When you visit our corporate website, aidem.com, AIDEM receives Data including your IP address and information about your browsing behaviour on our Website(s). If you fill out a form to connect with AIDEM over email (for example, to hear more about our products and services), we collect and store your name and email and use this Data to communicate with you for the express purpose described when you provided this Data. You can revoke your consent at any time and exercise your other privacy rights as outlined in Section 10 below. For more information on this, please refer to our Website and Cookie Notice.

More information on these three categories can be found below.

3. Types of data we access

Below is a list of Data we may Access solely for the provision of our Platform Services to our clients. We may not receive all of the information listed below every time we provide the Platform Services; the information we receive is predominantly determined by each Publisher with which you interact.

Online identifiers (IDs) – these are digital identifiers that may indirectly identify you and include:
- Pixels – HTML code snippets loaded when you visit a website that allows us to collect Data.
- Third-party online identifiers – IDs that belong to third parties. Third-party IDs may be associated to broad aggregate audience segments and shared with Buyers to serve more relevant ads to you based on your interests (e.g., ads related to sports or fashion).
Browser information – information including, but not limited to, the type and version of your browser, browser settings (such as language and local time), user agent, and your IP address.
Device Information – as applicable, general information including, but not limited to: device type (e.g., laptop, mobile, TV), model, manufacturer, operating system, time zone, telephone carrier information, network information (e.g., WIFI), and mobile application information.
Location information – geolocation information such as city, country, zip code/postal code, and/or longitude/latitude.

4. How we use your data

We Access your Data to provide our Platform Services. Please find described below the business purpose(s) for which we process Data, and our legal basis for doing so:

We Access your Data (per Section 3 above) for the following business purpose(s):

Ad delivery – to deliver ads to you on Publishers’ Digital Properties.
Ad reporting – to verify an ad was delivered to you with accuracy.
Troubleshooting, optimizing, and product improvement – to improve our Platform Services and ensure ads are delivered correctly to you.
Ad vetting – to prevent fraud, malware, and other unacceptable behaviour.
Privacy Rights – to view and enforce your opt-out choices, and honour your privacy choices/rights. For example, we may Access your Data if you make a request to delete your Data.

International law, such as European data protection law, requires us to have a legal reason for Accessing your Data. AIDEM Accesses your Data under one or more of the following legal bases:

Consent – AIDEM may Access your Data if you provide Publishers with the consent for us to do so. This means, for example, if you visit a website that has a cookie banner and click “Accept All”, AIDEM will receive a technical signal confirming that you are providing us with the consent to Access your Data.
Legitimate Interest – we may also Access your Data if we have a legitimate reason to do so. For example, we Access your Data to protect our Platform Services from unauthorized access. AIDEM will not override your privacy and/or fundamental rights and freedoms to exercise our legitimate interests.

5. How Your data is shared with our partners

We may disclose, share, or sell (collectively, Share) your Data with the following partners for the purpose of delivering ads to you:

Buyers - As noted above, we connect Publishers with Buyers of ad space. Buyers include Demand-Side Partners (other intermediaries) and Ad Partners (advertisers and ad agencies). We Share your data with Buyers to source ads that may be relevant to your interest(s). Buyers may Share your information with their clients and partners for the provision of their services. Each Buyer processes and Shares Data in accordance with their own privacy policies.
Quality Vendors - We may send your Data to third-party vendors that help maintain the integrity of our Platform Services; for example, by preventing malicious software (e.g., viruses, trojans), or traffic from non-humans (i.e., bots), from loading on the websites you browse.
Legal Reasons - We may be required to disclose your Data to comply with our legal obligations, or in cases where we believe in good faith that such disclosure is required by law.

How we protect your Data: If we Share your Data with another company, it becomes subject to their privacy practices which may differ from the information found in this Policy. To help protect your Data, AIDEM contractually requires Buyers to comply with applicable data protection and privacy laws and implement user-centric privacy practices.

6. International data transfers

While AIDEM is a global company, we will not transfer your Data internationally. We respect the security and confidentiality of your data and maintain data locality within European and US jurisdictions.

If for Legal Reasons, we are compelled to transfer data internationally, we will ensure the transfers of your Data are compliant with the laws of that region, including the European General Data Protection Regulation (GDPR).

7. California Residents

As a California Resident, you have the following rights under the California Consumer Privacy Act (CCPA):

You have the right to know and access:
- the categories of personal information and specific pieces of personal information we have collected,
- the categories of personal information we have disclosed for a business purpose to third parties in the preceding 12-months,
- the categories of sources from which we collect personal information,
- the business or commercial purpose for collecting, sharing, or selling your personal information, and
- the categories of third parties with whom we disclose, sell, or share personal information with;
You have the right to request deletion of personal information that we have collected, subject to certain exceptions;
You have the right to request correction of inaccurate personal information;
You have the right to opt out of the sale or sharing of your personal information; and,
You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the CCPA

8. Exercising your privacy rights

Please find details on how you can exercise your privacy rights below.

Access and deletion - You can access or delete the Data we may have about you using the details provided under the “Contact Us” Section.
Data portability - When you submit a request to access your information using the details provided under the “Contact Us” Section, AIDEM will provide your Data to you in a pdf/csv/json document.
Correct your data - You have the right to correct your Data using the details provided under the “Contact Us” Section. However, please note that any such correction is subject to our practical limitations. The Data we Access is in the form of technical identifiers and changing it can be impossible/impractical.
Object to accessing - The ads you see on Publisher Digital Properties may be tailored to your interests. AIDEM offers options to opt-out of (“stop” or “object to”) ‘interest-based’, or ‘personalized’ advertising using the details provided under the “Contact Us” Section. This ensures you will not receive advertising based on your personal interests. Kindly note, opting-out of personalized advertising does not mean you will no longer see online ads, it simply means you will not see ads tailored to your personal interest.
Right to lodge a complaint (in Europe) - AIDEM complies with our obligations under European data protection laws and makes every effort to ensure your rights are protected and respected. If you have any questions or complaints regarding our Data processing, please contact us using the details provided under the “Contact Us” Section.

You have a right to lodge a complaint with your local Data Protection Supervisory Authority if you wish to dispute the way we Access your Data. Please see the contact details of supervisory authorities below:

9. Data Security

The security, integrity, and confidentiality of your Data are extremely important to us. We implement technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. Such measures include but are not limited to: (a) encryption, (b) controls that limit the access of your data, both technically and at our physical data center locations, and also (c) by enabling information security practices such employee training on the safe handling of Data. We regularly review our security procedures to ensure the protection of your information. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. If you have reason to believe your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” Section below.

10. Data Retention

We retain your Data for the time needed to provide our Platform Services, or as otherwise required or permitted by law. Our maximum retention period is thirteen (13) months, after which we de-personalize Data by aggregating it, and these aggregate datasets cannot be traced back to individuals.

11. Corporate policy

The information in this section describes how AIDEM Accesses information applies to your interactions with us in a business capacity only. For example, if you are a client or business and you are engaging in a business relationship with AIDEM or if you are a candidate applying for an employment opportunity at AIDEM, this section applies.

Such business-related activities include when you: (a) register to become a member on the AIDEM client user interface; (b) attend an AIDEM sponsored event; and/or; (d) participate in a business relationship with AIDEM that requires the submission of your identifiable information to AIDEM (i.e., negotiating your business relationship with us, providing responses to our company surveys, etc.). Collectively, these are our Commercial Purposes for collecting your information. AIDEM may also collect your professional and academic background when you send us your CV/resume to work with us (Employment Purposes).

Information we collect

AIDEM may collect your full name, mailing and/or billing address, email address, company name, job title, department or job role, and similar contact data (your Identifiable Data) in the course of our business relationship with you.

We collect information about you in connection with Employment Purposes. Categories of information we may collect about you include, but are not limited to:

Contact information – name, address, telephone or mobile number, email address, and other contact information,
Employment and education – cover letter, résumé, CV, work experience, relevant experience, educational background, information from professional licensing and certification bodies,
Government issued ID or similar ID – citizenship, residency, and work permit status,
References – information from your previous employers or other references,
Background checks – information related to a background check,
Publicly available information – information you’ve made public such as a public profile on a career or networking site,
Assessments – mandatory assessment information such as interviews and skills tests, and
Voluntary Data – information you choose to provide voluntarily such as a voluntary opt-in candidate experience feedback survey.

Purpose and legal bases

Listed below are the purposes and legal bases for which AIDEM may Access your Identifiable Data in the course of our business relationship with you.

Management of the contractual or pre-contractual relationship - AIDEM uses your Identifiable Data to service accounts and respond to inbound inquiries related to sales or technical support requests and for billing purposes. This may include sharing inviting you to provide feedback to us using a third-party service provider. We may internally use Identifiable Data for analytical purposes, for example, to improve our UI or the services we provide to you. We may also use your Identifiable Data in the assessments of your CVs/resume and to manage our recruitment processes.
Legitimate interest - As applicable, we may use Identifiable Data to send you marketing and promotional communications (for clarity, this is not for Employment Purposes), to evaluate and improve our internal services, and to build our relationship with you.
Consent - Kindly note, you provide us with consent to use your Identifiable Data for the above Purposes and Employment Purposes when you participate in a business relationship with AIDEM.

We process information related to Employment Purposes to:

Process your application – we use your information to review and process your application,
Assess qualifications and suitability – we use information to assess your skills and qualifications,
Contact you – we may contact you for a current or future opportunity, to schedule interviews, and otherwise communicate with you relating to your application,
References, background checks, and as legally required – if you are offered a role, we use information to verify information you or others provide to complete background checks, verify eligibility to work in the country you applied for a role in, or check your references, and
Other purposes with consent.

Transfers of data

We may be required to disclose your Identifiable Data to comply with our legal requirements, or in cases where we believe in good faith that disclosure is required by law.

We may transfer your Identifiable Data internationally to any of our data center locations globally, ensuring that any international transfer of your Data is compliant with the laws of that region. When we transfer Identifiable Data outside of the EEA, we ensure that appropriate legal protections are in place under European data protection legislation. These protections may include technical measures, such as encryption, or a legal mechanism such as the Standard Contractual Clauses approved by the European Commission. For example, as part of the recruitment process, your information may be transferred to a member of our talent team located in another country.

Privacy rights

You retain your rights to access, correction, erasure, limitation, and objection of the processing of your Identifiable Data. You have the right to revoke consent granted to AIDEM at any time and to file claims with appropriate Data Protection Authority. Please not that all other rights described in this Policy also apply. For example, California Residents should review Section 7 and Section 8 of this Policy to better understand their rights and how to enforce them.

For more information and/or to exercise your rights, please contact us at [email protected]. If you do not wish to contact us by email, please see the “Contact Us” Section below for additional details.

Data Retention

AIDEM will only retain information for as long as it is necessary to carry out our intended Purposes as described herein. Any of the Identifiable Data you provide us through the channels will be deleted once it is no longer necessary to manage our business relationship with you. Any Identifiable Data retained is in compliance with our legal obligations and will only be shared if there is a legal obligation for us to do so, based on a request from the appropriate authorities.

Data Security

We implement technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to ensure the protection of your information. Please be aware, despite our best efforts, no security measures are perfect or impenetrable. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately in accordance with the “Contact Us” Section below.

Please note that all other sections of this Policy may also be applicable to the processing of your Data (for example, the Cookie and Website Notice below will also apply if you visit one of our websites).

This section explains AIDEM __cf_bm cookie usage.

Cloudflare’s bot products identify and mitigate automated traffic to protect our Website and Platform from bad bots. Cloudflare places the __cf_bm cookie on end-user devices that access our website and Platform protected by Bot Management or Bot Fight Mode. The __cf_bm cookie is necessary for these bot solutions to function properly.

This cookie expires after 30 minutes of continuous inactivity by the end user. The cookie contains information related to the calculation of Cloudflare’s proprietary bot score and, when Anomaly Detection is enabled on Bot Management, a session identifier. The information in the cookie (other than time-related information) is encrypted and can only be decrypted by Cloudflare.

A separate __cf_bm cookie is generated for each site that an end user visits, as neither AIDEM nor Cloudflare track users from site to site or from session to session using this cookie. The __cf_bm cookie is generated independently by Cloudflare, and does not correspond to any user ID or other identifiers in AIDEM's Website or Platform.

13. Self-Regulation Initiatives

AIDEM supports efforts for self-regulation in the digital advertising industry. AIDEM participates in the IAB’s Transparency & Consent Framework and complies with its specifications and policies (AIDEM’s identification number within the framework is 1218).

14. Changes to this policy

We may change this Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The date at the top of this Policy reflects the most recent changes made. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you, as required by applicable data protection and privacy laws.

15. Contact us

If you have any questions, concerns, or complaints related to our privacy policy or how we process your personal data, please contact us by e-mail at [email protected] or at the following address:

Attn: AIDEM Technologies LTD c/o Privacy 150 Fleet Street EC4A 2DQ United Kingdom