Privacy Policy
A. Privacy Policy for Non-EU-Citizens
- Information we collect
- How we use your information
- How we share your information
- Information retention
- Security of information
- Cookies and web beacons
- Do not track
- Third-party practices
- California consumer disclosure & rights (CCPA)
- Minors
- Changes to this privacy policy
- Complying with the laws of your jurisdiction
B. Privacy Policy for EU-Citizens
A. Privacy Policy for Non-EU-Citizens
For your convenience, we have summarized the important aspects of our Privacy Policy below, but you should read the entire Privacy Policy to fully understand our privacy practices.
We collect both Personal Information and Service Use Based Information from you in connection with your use of our Services. When you choose to share your Personal Information with us, we only use such information, to provide our Services or communicate our responses to any queries or requests made by you.
We may share your Service Use Based Information with third parties in a number of ways and for a number of reasons, including facilitating the provision of our Services to you, for our own uses and for this use by third parties. You can review our rights under this Privacy Policy to share your information in the Section below titled “How We Share Your Information” below.
You may review, modify and update your Personal Information or Service Use Based Information by contacting us at privacy@aax.media.
Information we collect
When you access or use our Services, we may collect information regarding your interactions with our Services. Such information may include Personal and Service Use Based Information.
“Personal Information” means information that you choose to share with us when you register to participate in AAX’s program, get paid or while communicating with us through the feedback form or any other mode of communication. Such information may include but is not limited to your name, email address, payment information. Please note that this information is only used by us to provide the Services or respond to any queries and request made by you and we do not collect Personal Information unless you submit that information to us.
“Service Use Based Information” means information that we collect from your use of the Services, including:
“Device Information”: The type of device you are using to access our Services, as well as information regarding that device’s unique identifiers (whether computer or mobile), the device’s hardware model, operating system, device type, IP address, and information about how any of our Services were downloaded to your device.
“Geolocation Information”: Your location when you use our Services, when such information is available. Additionally, we may be required to collect information about your location to provide certain features offered by our Services. We will collect such information only with your consent. Should you choose not to provide the consent to collect such information, certain features of our Services may not be available to you.
“Log Data”: Your device activity while using our Services, the times and duration of your use of our Services, the types of queries you submit through our Services, the referring URL from which you accessed our Services, the browser you used to access our Services, and the language used to access our Services.
“Cookies, Web Beacons, & Other Tracking Technologies”: To enable our collection of information, we often use web beacons, unique identifiers, web server log information, or other technologies. We may also collect information from and about you on behalf of third parties, who may use that information for targeting ads to you, optimizing their services and products, and general reporting. For more information on cookies, web beacons and other technologies, please read Section 6 of this Privacy Policy.
How we use your information
Your Personal Information held by us may be used for business and commercial purposes to:
a. contact you about our Services or make the features on our Services available to you or to communicate with you pertaining to your account in our system;
b. monitor the use of our Services and make required modifications and/or enhancements;
c. analyze the use of our Services and generate related reports to support the research;
d. ensure smooth and error-free functioning of our Services;
e. respond to any inquiries or support requests made by you;
f. enforce our rights;
g. prevent fraud and abuse against our Services (collectively, the “Legitimate Purpose(s)”)
Your Service Use Based Information held by us may be used for business and commercial purposes to:
h. share it with third parties such as advertising partners, ad networks, publishers, data providers and corporate affiliates in order to provide our services, conduct internal analysis to perform and improve our Services and associated technologies;
i. combine data we collect about you with data we obtain from our business partners, ad networks, and/or other companies such as data providers, including our corporate affiliates in order to provide our Services, conduct internal analysis in order to perform and improve our Services;
j. infer eligibility of users for interest, geographic and demographic-based segments;
k. present advertisements tailored to interests you have shown;
l. determine whether you have seen a particular advertisement before so as to avoid sending you duplicate advertisements;
m. identify fraud and malicious activity;
n. understand the patterns of people who see advertisements;
o. provide insights and reporting back to our business partners, including statistical reporting in connection with the activity on a website or mobile application, optimization of location of ad placement, ad performance, reach and frequency metrics, billing, and logging ads served on a particular day to a particular website or application;
p. evaluate the probability and nature of connections between devices; and
q. create online advertising models through lookalike modelling or similar research methodologies.
How we share your information
We may share your Service Use Based Information, with our commercial partners, who assist us in providing the features offered by our Services, including our services, advertising, and content partners (collectively, “Commercial Partners”) or allow those Commercial Partners to gather information directly from you.
Your Service Use Based Information may also be shared with third parties in other circumstances, including without limitation, as follows:
Commercial Partners: We may, with your consent, provide your information to our Commercial Partners who work with us to provide any portion of our Services, or to provide additional services unrelated to our Services. Should you choose not to permit the sharing of your information with our Commercial partners, some features of our Services may not be made available to you. As necessary under this Privacy Policy, our Commercial Partners are required to protect the information we provide them in a manner that is consistent with this Privacy Policy.
We may also rent, sell, or share aggregated Service Use Based Information that is not Personal Information with third parties for multiple reasons, including to develop and deliver targeted advertising and to conduct general business analysis. Information that we collect to create segments and profile information for our service may be shared with our Commercial Partners. We may combine information we collect with additional information collected from other sources. While we do not collect Personal Information about you when you view or interact with an advertisement, there is a possibility that our Commercial Partners will make assumptions or infer things about you (or anyone using your devices or browsers) in order to display more relevant ads.
Your Service Use Based Information and Personal Information may also be shared with third parties in other circumstances, including without limitation, as follows:
For Legal Requirements: Where it is necessary for us to address suspected fraud or illegal activities, to prevent or take action in connection with potential threats to the physical safety of any person, or to comply with any applicable law, we reserve the right to share your Personal Information, regardless of whether there is a court order, warrant or subpoena.
For Transactional Requirements: If the Company undergoes a change in control, reorganization or liquidation, or a sale of all or substantially all of our assets or a portion of our business or Services to which your information relates, we may transfer such information to our successor or buyer, subject to the terms of this Privacy Policy.
We disclaim and shall have no liability or obligation in connection with any third-party actions or omissions concerning your information, regardless of whether or not such access is a result of our sharing and disclosure of your information pursuant to this Privacy Policy. If you have any issues concerning a third party’s use of your information, please contact such third party. Any transfer of your information will comply with applicable law in all cases. For more information on third-party use of your information, please see Third-Party Practices herein.
We may share the information we collect about you with certain third parties in the following ways:
Information retention
We will only retain Service Use Based Information and Personal Information relating to you for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for such information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. Unless contrary to applicable laws, except with respect to information about our Commercial Partners with whom we have an ongoing relationship, our policy is to retain the non-aggregated information we collect for up to twenty four (24) months, after which the data is either anonymized or deleted from our systems. And as permitted by law, we may continue to retain aggregated information. In some circumstances, if you are an EU data subject, you can ask us to delete your Personal Information or Service Use Based Information by sending us an email to privacy@aax.media.
Usercentrics
Salesforce Customer Relationship Management (CRM) Service
LinkedIn Analytics Service
Google Analytics
Twitter Advertising Service
Security of information
We place appropriate restrictions on access to Personal Information stored by us and employ reasonable technical, physical and operational security measures intended to protect your personal information from alteration, loss, unauthorized use or misuse, or destruction.
To safeguard any information in transit, we use the SSL (Secure Socket Layer) technology to ensure encryption of all information transmissions from and to our servers.
Please note that no transmission of information over the internet is 100% secure. While we review our measures periodically and ensure that we implement safeguards and controls to store and transfer your information securely, we cannot warrant the security of any information transmitted from or to our servers.
Cookies and web beacons
In connection with your use of our Services, we may send your computer or mobile device a cookie that uniquely identifies your browser. A “cookie” is a small file containing your preferences that is sent to your browser and sent back by your browser each time your browser accesses our servers. Our use of cookies is primarily focused on improving the quality of our Services and your use of those Services.
Unless you choose to provide it to us, our technology and Services do not collection any sensitive consumer information about you during the ad delivery process. Our technology does not, for example, collect any social security numbers, insurance plan numbers, financial account numbers, precise real-time geographic location derived through location-based services, nor any specific information about your past, present, or potential future health or medical conditions or treatments, including genetic, genomic or family medical history.
We use session cookies (a type of cookie that is stored temporarily and gets deleted when a browser is closed) and persistent cookies (a type of cookie that is stored on the device till it expires or till the user deletes it) to deliver our Services in your language of choice, to filter results and fulfill other preferences you may have, and to analyze how our users interact with our Services by tracking user trends and patterns of how people search. Many browsers are set up to accept cookies unless the user changes the settings for cookies, and you can control these settings within your browser preferences or refuse cookies altogether.
We use Google Analytics, a web analysis service of Google, Inc., for measuring the effectiveness of our Services. In order to do so, we may permit Google Analytics to include their own cookies or similar tracking technologies to analyze data in connection with your use of our Services. We use this information to help us understand overall user preferences, click-through rates, means to improve our Services and discover the types of offers that are of most interest to our users. For detailed information on how Google collects and processes your information, please visit https://www.google.com/policies/privacy/partners/.
Do not track
Some browsers may allow you to enable a do-not-track feature that notifies the websites you visit that you do not want your online activities to be tracked. At present, our Services do not recognize or respond to ‘do-not-track’ signals from browsers.
Third-party practices
Our Commercial Partners may request or require you to provide information, including Personal Information or Service Use Based Information, to them in connection with the provision of our Services. We have no responsibility for the privacy practices of our Commercial Partners. To the extent any portion of our Services may also link to third-party websites and offerings over which we exercise no control, Company shall have no responsibility for the privacy practices or the content of such third-party websites and offerings, including their information collection, storage, usage and sharing practices. Please contact such third parties in connection with any issues you may have with respect to those third-party websites and offerings.
If you believe that any party who claims association with Company, including our Commercial Partners, is improperly collecting or using information about you, you should contact them directly. Applicable law obligates our Commercial Partners to protect the privacy of certain types of data. We are not responsible for their actions or omissions in any way, including with respect to any information they receive directly or indirectly from us. While we assume no responsibility with respect to a third party’s practices, you may notify us at privacy@aax.media if you believe a third party is collecting or using information about you and such information was sourced from us. We are under no obligation to respond to or pursue any action in connection with such correspondence.
California consumer disclosure & rights (CCPA)
Definitions
The terms “Business Purpose(s)”, “Personal Information”, “Sell” (or “Sale”), “Service Provider(s)” and “Third Parties” have the meanings given in the California Consumer Privacy Act of 2018 (CCPA). These term references and disclosures are limited to this section of the Privacy Policy and designated exclusively for California Consumers.
Categories of Personal Information
Unique device identifiers such as Cookies, Mobile Ad IDs (IDFAs for iOS and Android Ad IDs), Timestamps, User Agent Strings, IP addresses and general location data that is no more specific than a postal code, and web addresses (also known as “URLs”) or a mobile application where a user is browsing.
Purposes for collecting Personal Information
We collect personal information to deliver and measure online advertising.
Categories of sources from which Personal Information is collected
Websites, mobile applications, advertising services, technology platforms.
Purposes for use of collected Information
We use collected information to deliver and measure online relevant advertising.
Categories of Personal Information we sell
Identifiers and inferences about website visitors.
Purposes for selling personal information
This data is used by our Advertisers and Partners for more tailored advertising, marketing, measurement, analytics, and research.
Categories of Third Parties to whom Personal Information is sold
Advertisers, advertising agencies, marketers, technology platforms, and market research firms.
Categories of third parties to whom information was shared for a business purpose
Advertisers, advertising agencies, marketers, technology platforms, and market research firms.
California Consumer Rights & Options
Access or Delete Your Personal Information
Complete our rights exercise by emailing us at privacy@aax.media.
Opt Out of Sales or Exercise Your “Do Not Sell My Personal Information” Right Under CCPA
You can opt-out via our opt-out tool here.
Note: AAX may set a non-unique cookie for the sole purpose of implementing such opt-out request. If you opt-out, you should not delete your cookies. If you delete your cookies after opting out, you will need to opt-out again.
Minors
We at all times comply with the Children’s Online Privacy Protection Act (COPPA). Please click here for more information about COPPA and children’s privacy. Children under the age of 18 are prohibited from accessing the Services and may not give us any Personal Information or participate in any aspect of our Services. Our Services are not directed to children under the age of 18. Unless required by law, we will not knowingly collect, maintain, or disclose any Personal Information from children under the age of 18. We do not intentionally gather Personal Information about visitors or end-users who are under the age of 18. Please contact us at privacy@aax.media if you believe that we have collected Personal Information about a visitor or end user who is under the age of 18, and such account and/or Personal Information will be deleted.
Changes to this privacy policy
We reserve the right to revise this Privacy Policy at any time and for any reason. Your continued use of our Services after such change has been made will be considered your acceptance of such change.
Complying with the laws of your jurisdiction
Our Services may not be appropriate or available for use in certain jurisdictions and we disclaim all representations and warranties to the contrary. If you access the Services, you do so on your own initiative and at your own risk, and you are solely responsible for complying with all local laws, rules and regulations. We may limit access to our Services, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. By using our Services and submitting any Personal Information and Service Use Based Information, you consent to the transfer of Personal Information and Service Use Based Information to other countries, such as the United States, which may provide a level of data security different from your country of residence. You are also consenting to the application of United States law in all matters concerning the Services.
B. Privacy Policy for EU-Citizens
Your privacy is important to us. You should feel safe with us. Therefore, we and our data protection officer ensure compliance with the data protection requirements, in particular the European General Data Protection Regulation (GDPR). Below, we would like to inform you about the purposes for which your data is processed and how you can exercise your rights. You can access the Privacy Policy at any time via the “Data protection” tab at the bottom of each page.
Name and contact data of the controller
Controller is
AAX LLC
3343 Peachtree Rd NE Ste 145
(Atlanta Financial Center)-522
Atlanta, GA 30326, USA
Email: privacy@aax.media.
Appointed as representative in the EU is
Dr. Carlo Piltz,
Piltz Rechtsanwälte PartGmbB,
Mozartstraße 16, 12247 Berlin,
Email: gdprrep@aax.media
Contact data of our Data Protection Officer (DPO)
You can reach our data protection officer at:
Privacy@aax.media
Purpose and legal basis of data processing
When you access or use our Services, we collect information regarding your interactions with our Services. Such information include Personal and Service Use Based Information. Both “Personal Information” and “Service Use Based Information” are considered “Personal Data”.
“Personal Information” means information that you choose to share with us when you visit our website, register to participate in AAX’s program, get paid or while communicating with us through the feedback form or any other mode of communication. Such information include but is not limited to your name, email address, payment information. Please note that this information is only used by us to provide the Services or respond to any queries and request made by you and we do not collect Personal Information unless you submit that information to us.
The legal basis for these processing activities is our legitimate interest to display the content of our website to you as a visitor properly (Art. 6 (1) (f) GDPR), the fulfillment of the contract with you if you are our contract partner (Art. 6 (1) (b) GDPR) or your consent as an ad-blocker user by allowing in your ad-blocker the display of acceptable ads (Art. 6 (1) (a) GDPR).
These Personal Data processed by us are used for business and commercial purposes to
a. contact you about our Services or make the features on our Services available to you or to communicate with you pertaining to your account in our system;
b. monitor the use of our Services and make required modifications and/or enhancements;
c. analyze the use of our Services and generate related reports to support the research;
d. ensure smooth and error-free functioning of our Services;
e. respond to any inquiries or support requests made by you;
f. enforce our rights;
g. prevent fraud and abuse against our Services (collectively, the “Legitimate Purpose(s)”)
h. share it with third parties such as advertising partners, ad networks, publishers, data providers and corporate affiliates in order to provide our services, conduct internal analysis to perform and improve our Services and associated technologies;
i. combine data we collect about you with data we obtain from our business partners, ad networks, and/or other companies such as data providers, including our corporate affiliates in order to provide our Services, conduct internal analysis in order to perform and improve our Services;
j. infer eligibility of users for interest, geographic and demographic-based segments;
k. present advertisements tailored to interests you have shown;
l. determine whether you have seen a particular advertisement before so as to avoid sending you duplicate advertisements;
m. identify fraud and malicious activity
n. understand the patterns of people who see advertisements;
o. provide insights and reporting back to our business partners, including statistical reporting in connection with the activity on a website or mobile application, optimization of location of ad placement, ad performance, reach and frequency metrics, billing, and logging ads served on a particular day to a particular website or application;
p. evaluate the probability and nature of connections between devices; and
q. create online advertising models through lookalike modelling or similar research methodologies
r. to process transactions.
The Personal Data we process are in particular:
Device Information
The type of device you are using to access our Services, as well as information regarding that device’s unique identifiers (whether computer or mobile), the device’s hardware model, operating system, device type, IP address, and information about how any of our Services were downloaded to your device.
Geolocation Information
Your location when you use our Services, when such information is available. Additionally, we collect information about your location to provide certain features offered by our Services. We will collect such information only with your consent. Should you choose not to provide the consent to collect such information, certain features of our Services may not be available to you.
Log Data
Your device activity while using our Services, the times and duration of your use of our Services, the types of queries you submit through our Services, the referring URL from which you accessed our Services, the browser you used to access our Services, and the language used to access our Services.
Cookies, Web Beacons, & Other Tracking Technologies
To enable our collection of information, we often use web beacons, unique identifiers, web server log information, or other technologies. We also collect information from and about you on behalf of third parties, who use that information for targeting ads to you, optimizing their services and products, and general reporting.
In connection with your use of our Services, we send your computer or mobile device a cookie that uniquely identifies your browser. A “cookie” is a small file containing your preferences that is sent to your browser and sent back by your browser each time your browser accesses our servers. Our use of cookies is primarily focused on improving the quality of our Services and your use of those Services.
Unless you choose to provide it to us, our technology and Services do not process any sensitive data about you during the ad delivery process. Our technology does not, for example, collect any social security numbers, insurance plan numbers, financial account numbers, precise real-time geographic location derived through location-based services, nor any specific information about your past, present, or potential future health or medical conditions or treatments, including genetic, genomic or family medical history.
We use session cookies (a type of cookie that is stored temporarily and gets deleted when a browser is closed) and persistent cookies (a type of cookie that is stored on the device till it expires or till the user deletes it) to deliver our Services in your language of choice, to filter results and fulfill other preferences you may have, and to analyze how our users interact with our Services by tracking user trends and patterns of how people search. Many browsers are set up to accept cookies unless the user changes the settings for cookies, and you can control these settings within your browser preferences or refuse cookies altogether.
Please click here to access our Opt-Out page to read more information about cookies and how to opt-out of cookies in various browsers, such as Internet Explorer, Firefox, Safari, Opera and Chrome.
Recipients of data
We transfer data to our processors in order to have them fulfill the contractual obligations such as external web hosting services.
We share data, with our commercial partners, who assist us in providing the features offered by our Services, including our services, advertising, and content partners (collectively, “Commercial Partners”) or allow those Commercial Partners to gather information directly from you.
Your Service Use Based Information are also shared with third parties in other circumstances, including without limitation, as follows:
Commercial Partners
With your consent, we provide your information to our Commercial Partners who work with us to provide any portion of our Services, or to provide additional services unrelated to our Services. Should you choose not to permit the sharing of your information with our Commercial partners, some features of our Services may not be made available to you. As necessary under this Privacy Policy, our Commercial Partners are required to protect the information we provide them in a manner that is consistent with this Privacy Policy.
We also rent, sell, or share aggregated Service Use Based Information that is not Personal Information with third parties for multiple reasons, including to develop and deliver targeted advertising and to conduct general business analysis. Information that we collect to create segments and profile information for our service are shared with our Commercial Partners. We combine information we collect with additional information collected from other sources. While we do not collect Personal Information about you when you view or interact with an advertisement, there is a possibility that our Commercial Partners will make assumptions or infer things aboutyou (or anyone using your devices or browsers) in order to display more relevant ads.
Our Commercial Partners request or require you to provide information, including Personal Information or Service Use Based Information, to them in connection with the provision of our Services. We have no responsibility for the privacy practices of our Commercial Partners. To the extent any portion of our Services may also link to third-party websites and offerings over which we exercise no control, we shall have no responsibility for the privacy practices or the content of such third-party websites and offerings, including their information collection, storage, usage and sharing practices. Please contact such third parties in connection with any issues you may have with respect to those third-party websites and offerings.
If you believe that any party who claims association with us, including our Commercial Partners, is improperly collecting or using information about you, you should contact them directly. Applicable law obligates our Commercial Partners to protect the privacy. We are not responsible for their actions or omissions in any way, including with respect to any information they receive directly or indirectly from us. While we assume no responsibility with respect to a third party’s practices, you can notify us at privacy@aax.media if you believe a third party is collecting or using information about you and such information was sourced from us we are under no obligation to respond to or pursue any action in connection with such correspondence.
List of our commercial partners:
• Media.net,
• Ad-Pushup,
• Index Exchange,
• Magnite,
• Pubmatic, ROI Media,
• OpenX,
• Sharethough,
• Synacor,
• 33Across,
• OneTag,
• YieldMo,
• 152 Media,
• OneTag,
• EngageBDR.
Data Retention
We will only retain Personal Data relating to you for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for such information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. Unless contrary to applicable laws, except with respect to information about our Commercial Partners with whom we have an ongoing relationship, our policy is to retain the non-aggregated information we collect for up to twenty four (24) months, after which the data is either anonymized or deleted from our systems. And as permitted by law, we may continue to retain aggregated information. In some circumstances, if you are an EU data subject, you can ask us to delete your Personal Information or Service Use Based Information by sending us an email to privacy@aax.media.
Security of information
place appropriate restrictions on access to Personal Information stored by us and employ reasonable technical, physical and operational security measures intended to protect your Personal Information from alteration, loss, unauthorized use or misuse, or destruction.
To safeguard any information in transit, we use the SSL (Secure Socket Layer) technology to ensure encryption of all information transmissions from and to our servers.
Please note that no transmission of information over the internet is 100% secure. While we review our measures periodically and ensure that we implement safeguards and controls to store and transfer your information securely, we cannot warrant the security of any information transmitted from or to our servers.
Do not track
Some browsers may allow you to enable a do-not-track feature that notifies the websites you visit that you do not want your online activities to be tracked. At present, our Services do not recognize or respond to ‘do-not-track’ signals from browsers.
Data subject rights
As data subject you have the following rights:
Right to object
According to Art. 21 (1) GDPR, you have the right to object to the processing of your Personal Data based on Art. 6 (1) (f) GDPR at any time for reasons arising from your particular situation.
If you object, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
Right to Withdraw Consent
If a processing activity of your Personal Data is based on your consent, you may withdraw your consent at any time without reason (Art. 7 (3) GDPR). Please note that this does not affect the processing of your Personal Information and Service Use Based Information prior to the withdrawal of your consent.
In order to withdraw your consent please contact us via the contact addresses above or click here to access our Opt-Out page to read more information about cookies and how to opt-out of cookies in various browsers, such as Internet Explorer, Firefox, Safari, Opera and Chrome.
You have the following additional rights with regard to your processed Personal data if the respective specific prerequisites are met with respect to the controller:
• Right of access, Art. 15 GDPR;
• Right to rectification, Art. 16 GDPR;
• Right to erasure (‘right to be forgotten’), Art. 17 GDPR;
• Right to restriction of processing, Art. 18 GDPR;
• Right to data portability, Art. 20 GDPR.
Furthermore, you also have the right to lodge a complaint with a supervisory authority if you believe that the processing of Personal Data concerning you is in breach of the GDPR.
Changes to this privacy policy
privacy policy must be adapted from time to time to the actual circumstances and the legal situation. Please check the data protection declaration before you use our offer in order to be up to date with possible changes or updates.