1. Introduction - Mediasmart Mobile, S.L. - US Privacy Policy Supplement
At Mediasmart, we take the fundamental rights of end-users and employees (the “Data Subjects”) very seriously and we are committed to protecting and respecting your privacy and your privacy rights.
This is our Privacy Notice for our Self Serve Programmatic Platform for incremental growth (the “Platform”) as well as the general website you find at https://mediasmart.io, and it explains when and how we collect Personal Data about people who: a) visit our website and/or use our services through website and on-line servers and b) are exposed to the advertisements (“Ads”) provided by our clients in which we enable the technical serving process. It also explains how we use such Personal Data, the conditions under which we may disclose it to others and how we intend to keep it secure. It describes the processing activities carried out by Mediasmart, the purposes for which these activities are performed and the legal basis that Mediasmart relies upon to justify these processing activities.
This policy applies to consumers in the US, who are subject to various state privacy laws such as:
- California, via the California Consumer Privacy Act (“CCPA”)
- Virginia, via the Virginia Consumer Data Protection Act (“VCPA”)
- Connecticut, via the Connecticut Data Privacy Act (“CDPA”)
- Utah, via the Utah Consumer Privacy Act (“UCPA”)
- Colorado, via the Colorado Privacy Act (“CPA”)
This policy supplements the Mediasmart general privacy policy.
Mediasmart participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Mediasmart’s identification number within the framework is 193.
We keep this Privacy Supplement under regular review and its scope and contents might evolve from time to time. Please kindly check this page occasionally to ensure that you’re up to date with any changes. Mediasmart’s Privacy Suplement for the US was last updated on May, 2024.
Any questions regarding this Policy and our privacy practices should be sent by email to: legalmediasmart.io
2. Who we are
We are Affle Iberia, S.L. (“Mediasmart”) a software as a service platform for advertisers, agencies and companies seeking to dramatically improve their digital advertising strategies. We are an Affle company. We provide our services to our clients, who are either advertisers themselves or media buyers. The Platform helps our clients display relevant digital advertising to end users who interact with them. We are a Spanish limited liability company, with tax ID number B-86329638 and our registered address on: Calle Garcia de Paredes 12, 1ºB, 28010, Madrid.
3. What data do we collect and process from you?
Please refer to section 3 (“What data do we process?”) and 4 (“What data is collected from you?”) of our general Privacy Policy for more information on how we collect and process your data.
Generally, we only process your personal data provided to us by our partners with your prior consent, in line with the applicable law in your state. Any geolocation data processed is done with your consent.
4. Sale of Personal Data
For information about the specific categories of personal data we collect, please refer to section 3 (“What data do we process?”) and section 4 (“What data is collected from you?”) of our general Privacy Policy.
Categories of data sold include:
- Cookie information
- IP address
- Geo-location while being exposed to an ad
- Mobile Advertising IDs
5. Your rights
The rights listed in our general Privacy Policy cater to the European General Data Protection Regulation (“GDPR”). As a US-based visitor, consumer or customer you may have other rights that apply to you depending on where you are based.
California
Right to access: You may request access to, or a copy of, your personal data that we collect and/or sell.
Right to correction: You may request the correction of any incorrect personal data being processed about you.
Right to deletion: You may request the deletion of any personal data that we collect and/or sell.
Right to non-discrimination: You have the right to not be discriminated against based on your personal data.
Right to opt out: You have the right to opt out of your personal data being shared or sold. You may also opt out of your personal data being used for the purposes of profiling or automated decision-making.
Right to limit: You have the right to limit the processing of your sensitive personal data.
Right to limit sensitive data processing: You have the right to limit the processing of sensitive personal data.
Virginia
Right to access: You may request access to, or a copy of, your personal data that we collect and/or sell.
Right to correction: You may request the correction of any incorrect personal data being processed about you.
Right to deletion: You may request the deletion of any personal data that we collect and/or sell that was provided by or obtained about you, the consumer.
Right to non-discrimination: You have the right to not be discriminated against based on your personal data.
Right to opt out: You have the right to opt out of your personal data being shared or sold for purposes of targeted advertising and the sale of personal data. You may also opt out of your personal data being used for the purposes of profiling or automated decision-making.
Right to limit sensitive data processing: The processing of your sensitive personal data requires explicit consent.
Connecticut
Right to access: You may request access to, or a copy of, your personal data that we collect and/or sell.
Right to correction: You may request the correction of any incorrect personal data being processed about you.
Right to deletion: You may request the deletion of any personal data that we collect and/or sell about you.
Right to non-discrimination: You have the right to not be discriminated against based on your personal data.
Right to opt out: You have the right to opt out of your personal data being shared or sold for purposes of targeted advertising and the sale of personal data. You may also opt out of your personal data being used for the purposes of profiling or automated decision-making.
Right to limit sensitive data processing: The processing of your sensitive personal data requires explicit consent.
Utah
Right to access: You may request access to, or a copy of, your personal data that we collect and/or sell.
Right to deletion: You may request the deletion of any personal data that we collect and/or sell about you.
Right to non-discrimination: You have the right to not be discriminated against based on your personal data.
Right to opt out: You have the right to opt out of your personal data being shared or sold for purposes of targeted advertising and the sale of personal data.
Right to limit sensitive data processing: You have the right to limit the processing of your sensitive personal data.
Colorado
Right to access: You may request access to, or a copy of, your personal data that we collect and/or sell.
Right to correction: You may request the correction of any incorrect personal data being processed about you.
Right to deletion: You may request the deletion of any personal data that we collect and/or sell about you.
Right to non-discrimination: You have the right to not be discriminated against based on your personal data.
Right to opt out: You have the right to opt out of your personal data being shared or sold for purposes of targeted advertising and the sale of personal data. You may also opt out of your data being used for certain types of profiling or automated decision-making.
Right to limit sensitive data processing: The processing of your sensitive personal data requires explicit consent.
6. How to exercise your rights
You can exercise your rights at any time by contacting us at legal@mediasmart.io. We will respond to your request in accordance with our obligations under applicable privacy laws.
We may require you verify your identify in order to process your request, depending on which request you are exercising. Generally, we will only need your Mobile Advertising ID.
We may deny your access request if you are sending excessive or repetitive requests. In these cases, we will explain why we are not responding to your request and justify why we believe the request is unlawful.
7. Do not Track Signals
Mediasmart refrains from monitoring its customers' activities across third-party websites to deliver targeted advertisements. Consequently, Mediasmart does not acknowledge or act upon Do Not Track (DNT) signals.
In cases where third parties, including those with embedded content such as social features, operate on Mediasmart's websites, they may set cookies on a user's browser or gather information indicating that the web browser accessed a particular Mediasmart website from a specific IP address. It's important to note that third parties are unable to collect any additional personally identifiable information from Mediasmart's website unless explicitly provided by the user.