Legal

Privacy Policy

Adello is committed to protecting user privacy. We comply with all applicable data protection legislations including the European Data Protection Regulations (GDPR), and take a proactive stance by applying those in all our markets around the world.

The following Privacy Policy provides information about Adello and our mobile advertising platform AdCTRL, explains who we are, how we collect, share and use information, and how users can exercise their privacy rights. The Privacy Policy applies to information that we collect through our website www.adello.com ("Website"), or process in the course of providing our products and services through our Mobile Advertising Platform AdCTRL ("AdCTRL").

What does Adello do?

Adello operates AdCTRL, a transparent and neutral mobile advertising platform which is based on Adello's artificial intelligence technology and facilitates the creation and execution of mobile advertising campaigns on advertising spaces of numerous publications which are partly represented by intermediaries (eg. Ad Exchanges), and sold by Adello.

Adello uses AdCTRL for real-time large-scale data processing. This ensures that advertisers and their intermediaries (eg. media agencies) are enabled to place ads based on predicted interests, affinities and local context, and measure the effectiveness of their campaigns. Our aim is to reduce the number of ads that aren't beneficial or of interest to users.

AdCTRL is not a data provider, nor a media agency nor an ad network. AdCTRL is not built on cookies. The platform is operated in the EU and has been developed with user privacy at the core of its design from day one. It is subject to GDPR and applicable national data protection laws.

What information do we collect and why?

As a general rule, we aim not to collect any information which would put us into the position of being able to identify an individual. We may deviate from this rule only where we have the users consent, where we need the information to provide our contractual obligation to them or where we have a legitimate interest to do so.

a) Information collected on the Website

At the user's discretion, they can provide us with information, and some information is automatically provided by the user's internet browser when they visit the Website.

Type of InformationWhy We Use It
Name, E-mail, Company, Position, Phone, Country To provide requested services (newsletter, downloads) and to maintain client accounts.
Browser type & version, OS, Referrer URL, Pages accessed, Date/time, IP address (anonymized) Internal analytics, retargeting, measuring marketing campaign success, improving website quality and relevance.

If we require personal information not described above, the user will be asked for their consent, and the reasons will be made clear at the point of collection.

We use the analysis tool Matomo (Piwik) for anonymized analysis of website usage. The collected data is anonymized (IP addresses are masked) and stored in the EU on our own servers. It is not shared with any third-party nor sent outside of the EU. You can opt out here. We respect the "Do-not-Track" setting of your browser.

b) Information processed through AdCTRL

The information processed by AdCTRL is usually submitted by the publishers or their intermediaries (eg. Ad Exchanges) via application programming interfaces ("API"). AdCTRL uses this information to place ads on behalf of advertisers. The information consists of pseudonymous data associated by Mobile Advertising IDs and IP Addresses to users' mobile devices. The data does not allow Adello to identify individuals.

Type of InformationWhy We Use It
Mobile Advertising ID, Location Data, IP Address (anonymized), Pixel Tags, Statistical IDs, Audience Data Segments Location-based ad customization, interest-based advertising, ad response measurement, aggregated campaign statistics, platform operation and enhancement.

GDPR: Legal basis for processing

Our legal basis for collecting and processing information depends on the information concerned and the specific context. In accordance with the European GDPR, we collect and process personal information only where we have the user's consent (Art. 6 para 1 lit. a GDPR), where we need it to provide our contractual obligation (Art. 6 para 1 lit. b GDPR) or where we have a legitimate interest to do so (Art. 6 para 1 lit. f GDPR), provided these interests are not overridden by the user's data protection rights or fundamental freedoms.

Who do we share user information with?

  • On behalf of our clients and partners, where a user actively and willingly submits information in response to an ad. Such information is subject to that client's privacy practices.
  • Subsidiaries and third-party service providers who provide data processing services to us or support us in providing our services.
  • Competent law enforcement bodies, regulatory or government agencies, or courts where disclosure is necessary as a matter of applicable law or regulation, to exercise or defend our legal rights, or to protect vital interests.
  • A potential buyer (and its agents and advisors) in connection with any proposed purchase, merger or acquisition of any part of our business.

Links to Third-Party Websites

The Website may contain links to other websites. Adello is not responsible for the privacy practices of these third-party websites. Via AdCTRL we provide ads that link to third-party sites, apps, or other content. This Privacy Policy does not extend to third-party content or services.

Children's Privacy

Adello does not knowingly collect any personal information from children under age of sixteen (16). If you believe your child has provided Adello with personal information, please contact us using the details below.

Security and International Data Transfer

Adello utilizes hashing, encryption and de-identification techniques to help ensure data is safeguarded at all times. We enforce generally accepted industry security standards on AdCTRL to protect information both during transmission and once it is received.

Our servers are located in the European Union, the United States of America, and in Hong Kong. For users located in the EEA, we have implemented the European Commission's Standard Contractual Clauses ("SCC") for transfers of personal information. Users can obtain a copy of the SCC by contacting us below.

How long do we keep user information?

We retain personal information as long as we have an ongoing legitimate business need (for example, to provide a requested service or comply with legal, tax or accounting requirements). Information transferred by third parties will be deleted after a maximum period of 13 months or earlier. Summarized (aggregated statistical) data used for financial reporting is kept indefinitely.

User data protection rights

  • Opt out from ad tracking in general or from AdCTRL in particular via our opt-out page.
  • Access, correct, update or request deletion of personal information collected on the Website by contacting us below.
  • Object to processing, request restriction, or request portability of personal information (EEA users).
  • Unsubscribe from marketing communications via the "unsubscribe" link in our e-mails.
  • Complain to a data protection authority. Contact details for DPAs in the EEA, Switzerland and certain non-European countries are available here.

Contact Us

If you have any questions about our use of your personal information or about privacy on AdCTRL, please contact our Data Protection Representative at: privacy@adello.com

Adello Group AG Data Controller

Forchstrasse 32
8008 Zürich, Switzerland

Adello Technologies GmbH Data Processor

Haid-und-Neu-Str. 7
76131 Karlsruhe, Germany

Last updated: June 4, 2019