Privacy Policy

Last updated: June 26, 2020

Advertising Distribution Supplies SRL (“us”, “we”, or “our”) operates https://advertisingdistributionsupplies.com (the “Site”).  You must be at least 18 years old to use the Site.

We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on how and why we collect, store, use, and share your personal information when you use this Site. It also explains your rights in relation to your personal information and how to contact us.

By accessing, using, or submitting information to the Site, you agree to this Privacy Policy and our Terms.

Personal Information We Collect About You

We collect, use and are responsible for certain personal information about you, that identifies, relates to, describes, is reasonably capable of being associated with you, or that which could reasonably be linked, directly or indirectly, with a particular consumer or household. When we do so, we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union, and we are responsible as “controller” of that personal information for the purposes of those laws.

We collect, and have collected personal information about our visitors within the preceding 12 months in the following categories:

Categories of Personal InformationExamples of Specific Types of Personal Information CollectedCategories of Sources from Which PI is CollectedBusiness or Commercial Purpose for Which Each Category Will be Used
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers), or information that identifies, relates to, describes, or is capable of being associated with, a particular individual

First name;

Last name;

Email address; and

Your Internet Protocol (“IP”) address

Individual through the Site;

Internet service providers (ISPs);

Data analytics providers; and

Operating systems and platforms

 

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)Information you volunteer to the Site or through other means of communication, such as your subscription, comments/posts, written correspondence or other electronic submissions, and communications sent by you to the Site

Individual through the Site;

Internet service providers (ISPs);

Data analytics providers; and

Operating systems and platforms

 

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement)

Mobile and/or operating device identifier;

Computer operating system;

Source URL:

Referring website;

Web browser type and version;

Internet service provider (ISP);

Date and time stamp;

Mobile carrier; and

Behavioral data (opens, clicks)

 

Individual through the Site;

Internet service providers (ISPs);

Data analytics providers; and

Operating systems and platforms

 

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

Geolocation data

Geographic region based on IP address and/or web browser type; and

Area code and zip code associated with your web server

 

Individual through the Site;

Internet service providers (ISPs);

Data analytics providers; and

Operating systems and platforms

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

As noted in the above chart, we collect the above personal information directly from you via the Site, and from your interactions with the Site, including any personal information which you provide directly or indirectly.

Indirectly

Cookies and Tracking Pixels on the Site: We use and store cookies and tracking pixels on the Site, as described further. A cookie is a small data text file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and which is stored on your computer's web browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can later be retrieved to identify you to us. Personal information that we store about you may be linked to the information stored in and obtained from cookies. Cookies make your use of the Site easier, make the Site run more smoothly, and help us to maintain a secure Site. Tracking pixels (also known as web beacons, 1x1 pixels, or clear GIFs) are code requiring a call back to a server to render, and which deliver information to us about your IP address and information from your browser. Cookies and tracking pixels are used to track your interaction with the Site, including clicks. Cookies and tracking pixels may collect information about you, such as your IP address, your browser type and version, computer operating system, your ISP, the date and time of your visit to the Site, referring domain names and websites, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, and behavioral data (opens, clicks). We collect information on whether you responded to particular content or a particular advertisement featured on the Site, and which content and links you click through the Site through the use of tracking pixels.

Cookies and Tracking Pixels in Our Emails: Apart from use of the above technologies on our Site, we automatically collect information when an individual opens one of our emails, through the use of cookies and tracking pixels. We also automatically collect information on whether the individual clicked on any links within such emails.

To the extent that you click on a third party advertisement, or a particular product or service featured on the Site or in any email communication, we collect information on which link you clicked. We may receive a commission based on your interaction with links featured on the Site and in any email communications.

Tracking and How We Respond to Do Not Track Signals

You can instruct your web browser to refuse all cookies or to indicate when a cookie is being sent, by visiting the preferences or settings page of your web browser. In the event that your browser requests that we do not track you or store a cookie, unless otherwise required by law to honor the requests, we do not guarantee that our Site will honor such requests. Please note that we do not guarantee that the Site will work properly in the event that you elect to opt out of our tracking or use of cookies.

Directly

  • To the extent that you subscribe to receive email communications from us, we collect the personal information that you submit in connection with your subscription, including your name and email address, and may use such to send you email communications. In connection with your subscription, we also collect information on whether you viewed the email communications and clicked on any links within such email communications. You have the right to opt-out of receiving email communications from us at any time by either contacting us at the contact information below, or by clicking on the unsubscribe link in any emails. If you request to unsubscribe from receiving further email communications from us, we add your email address to our suppression file, to comply with CAN-SPAM.

 

  • To the extent that you post comments on the Site or reply to content featured on the Site, we collect the post or reply and the personal information that you submit in conjunction with your post, including your name, email address, and website address.

 

  • To the extent that you like or follow one of our social media profiles by clicking on the button featured on the Site, we may link such activities and any personal information with the personal information we have collected.

 

  • To the extent that you like or share content featured on the Site through social media sites or other third party sites by clicking on the buttons featured on the Site, we may link such activities and any personal information with the personal information we have collected.

 

  • To the extent that you share content featured on the Site via email sent through our Site, we may collect your name, your email address, any remarks, your friend’s name, and your friend’s email address.

 

  • To the extent that you contact us through the Site, we collect the personal information you submit, including your name and email address.

From Third Parties

As noted above in the chart, in addition to collecting personal information through the Site, we also collect personal information through third party Internet service providers (ISPs), data analytics providers, and operating systems and platforms.

How We Use Collected Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g., to comply with our legal and regulatory obligations; for our legitimate interests or those of a third party; or where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We may use information collected through your use of the Site for the business or commercial purposes described in the above chart. We use the information collected through the Site to track your access and interaction with the Site and featured content on the Site. We may share the information collected through your use of the Site with our third party advertising partners, such as advertising networks and service providers, such as data hygiene companies.

We and our third party advertising partners may collect and use non-personally identifiable information about you through cookies and tracking pixels, including the referring website address and whether you responded to particular content featured on the Site, and which links you click through the Site. We and our third party advertising partners also automatically collect information when an individual opens an email from us, through the use of cookies and tracking pixels, for the purpose of tracking clicks/conversions. As noted above, in the event that your web browser requests that we do not track you or store a cookie, unless otherwise required by law to do so, we do not guarantee that our Site will honor such requests.

We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

With Whom Do We Share Your Information

We may share the above information internally with our parent company and any subsidiary and affiliated companies. We may also share the above information with our third party advertising partners, such as advertising networks and service providers, such as data hygiene companies.

To the extent that you request to unsubscribe from receiving email communications from us, we may share your email address with our advertising partners, such as third party advertising networks, to effectuate your request to unsubscribe and to comply with CAN-SPAM.

To the extent that our third party advertising partners, such as advertising networks, request opt-in proof, we will disclose identifiers, or information that identifies, relates to, describes, or is capable of being associated with, a particular individual, and geolocation information, namely, email address, first name, last name, IP address, and signup location and date. We may also share the information collected through your use of the Site with third party data hygiene companies.

Also, on occasion, we may be required by law enforcement or judicial authorities to provide information to the appropriate governmental authorities. In the event of a merger, acquisition, or sale of our business, your data may also be transferred. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

Cross-Border Transfer

The Site is controlled and operated from outside of the United States, and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of Romania. Your data may be held, transferred to, processed, and maintained on computers located in Romania, as well as outside of the European Economic Area (EEA), and outside of your state, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. To deliver services to you, it may be necessary for us to share your personal information outside of the EEA, including with third party providers located outside the EEA, if you are based outside of the EEA, etc. We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Security

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security. As a result, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control; the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed; and any such information and data may be viewed or tampered with in transit by a third party. We make no warranty, express, implied, or otherwise, regarding the security of the Site and your personal information.

Third Party Links and Advertisements

The Site contains links to third party websites. We are not responsible for the privacy practices or the content of such third party websites. This Privacy Policy only addresses our use and disclosure of information which we collect from you. The third party websites which are accessible through our Site, and companies to whom your information is transferred, have their own privacy policies and data collection, use and disclosure practices. Please consult each third party website's privacy policy. We are not responsible for the policies or practices of third parties or their sites.

Children

You must be an adult of 18 years or older to use the Site. We do not target the Site to children. Consistent with the federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly collect personal information from anyone under the age of 13 without requesting parental consent.  If you are aware that your minor child under the age of 13 has provided us with personal information, please contact us.

Your Rights Under the GDPR (for individuals located in the EEA)

Right to AccessThe right to be provided with a copy of your personal information (the right of access)
Right to RectificationThe right to require us to correct any mistakes in your personal information
Right to be ForgottenThe right to require us to delete your personal information—in certain situations
Right to Restriction of ProcessingThe right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data PortabilityThe right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object

The right to object:

¾    at any time to your personal information being processed for direct marketing (including profiling);

¾    in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-MakingThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The National Supervisory Authority for Personal Data Processing is the supervisory authority in Romania and may be contacted at:

28-30 Magheru Blvd.

Bucharest, Section1

Romania

California Residents – Your Privacy Rights

If you are a California resident under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations, your use of the Site is subject to the California Consumer Privacy Act (“CCPA”), and all final, implementing regulations.

Under the CCPA, up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. Information regarding our collection and disclosure practices are detailed herein, in addition to instructions on how to exercise your rights regarding your personal information.

What Personal Information Do We Collect?

We collect, and have collected personal information about our visitors within the preceding 12 months in the following categories, and for the following business or commercial purposes:

Categories of Personal InformationBusiness or Commercial Purpose for Which Each Category Will be Used
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers), or information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement)

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

Geolocation data

Provide you with the ability to access and interact with the Site;

Maintain your account;

Track Site access and interaction;

Fulfill requests submitted through the Site;

Personalize and improve the Site;

Advertising/marketing;

Internal database;

Analytics;

Detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;

Debug to identify and repair errors that affect functionality of the Site;

Tracking consumer interaction with the Site (counting ad impressions, verifying positioning and quality of ad impressions, etc.); and

Legal compliance

We collect, use, and are responsible for certain personal information about you, that identifies, relates to, describes, is reasonably capable of being associated with you, or that which could reasonably be linked, directly or indirectly, with a particular consumer or household. Additional information about our collection of information through the Site can be found under the “Personal Information We Collect About You” heading above. In addition to collecting personal information through the Site, we also collect personal information through third party Internet service providers (ISPs), data analytics providers, and operating systems and platforms.

What Personal Information Do We Disclose or Sell?

Within the preceding 12 months, we have disclosed personal information to the third parties identified under the “With Whom Do We Share Your Information” heading above. We may disclose your personal information in any of the above categories if legally required to do so, in our sole discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public. Also, in the event that we, or substantially all of our assets, are acquired, personal information in all of the above categories may be included within the transferred assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such personal information in all of the above categories in a transaction approved by the court.

Under the definitions of “Sell” and “Sale” in the CCPA, we do not sell your personal information. However, in the event that we, or substantially all of our assets, are acquired, such personal information may be included within the transferred assets. Further, in the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.

Your Right to Request to Know and How to Submit a Verified Request to Know

A “request to know” is a request related to the personal information that a business has about such consumer. It may include a request for any or all of the following from us:

  • specific pieces of personal information that we have collected about you;
  • categories of personal information that we have collected about you;
  • categories of sources from which the personal information was collected;
  • categories of personal information that we have sold or disclosed for a business purpose about you;
  • categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.

The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.

To submit a request to know, please click here: https://advertisingdistributionsupplies.com/contact/ , or email us at
rtk@advertisingdistributionsupplies.com. To process your request, we may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required.

Your Right to Request Deletion and How to Submit a Verified Request to Delete

You have the right to request the deletion of any personal information which we have collected about you. To submit a verifiable request to delete, please click here: https://advertisingdistributionsupplies.com/contact/, or email us at rtd@advertisingdistributionsupplies.com. To process your request, we may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for deletion, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to delete will be used for the express purposes of verification and fulfilling your request, if required.

We utilize a two-step process for online requests to delete, whereby you first submit your request to delete, and second, you separately confirm that you want your personal information deleted.

To the extent that your personal information is necessary for us to maintain for a reason delineated in Cal. Civ. Code § 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, we are not required to comply with your request for deletion. For instance, we are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from us. If we are unable to verify your request, we will notify you as well.

Your Right to Non-Discrimination for the Exercise of Your Privacy Rights

California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. However, a business may offer a financial incentive or price or service difference if it is reasonably related to the value of the consumer’s data. A business shall notify consumers of any financial incentive or price or service difference.

Updates

This Privacy Policy was published and last updated on June 26, 2020. We may update this Privacy Policy from time to time. Updates to this Privacy Policy are effective when they are posted. You acknowledge and agree that it is your responsibility to review this Site and this Privacy Policy periodically and to be aware of any modifications. Your use of the Site after such modifications will constitute your acknowledgment of the modified Privacy Policy; and agreement to abide and be bound by the modified Privacy Policy.

Contact Us

If you would like to exercise any of your rights as described in this Privacy Policy, or if you have any questions or concerns regarding your privacy rights or our Privacy Policy or practices, you may contact us via email at privacy@advertisingdistributionsupplies.com, or by mail at Calea Unirii 31 A, Suceava, SV 720166 – Romania.

Need More Information or Do You Need Extra Help?

Further, if you have a disability which interferes with your ability to access this policy, we can make accommodations to present the policy in an alternative format to assist you. If you would like to receive this Privacy Policy in another format that is accessible to your needs (for example: audio, large print, etc.), please contact us.