This policy indicates "we", "us" or "our" to refer to AceeX SP.Z.O.O., a full-stack programmatic digital media company, the global DSP and SSP platform provider with its primary headquarter located at New York, US.

Developing our innovation-driven products, we aim to transform, improve, and support the current state of programmatic advertising worldwide, letting the publishers and advertisers a chance to maximize their yield and increase the effectiveness of their ad campaign performance.

AceeX SP.Z.O.O. operates strictly in accordance with the principles of the personal data protection legislation and fully commits to the GDPR data protection standards obtaining and processing the personal data of EU residents.

AceeX SP.Z.O.O. accepts responsibility for managing the personal data of our customers. This privacy policy will disclose the order in which we process your personal identification data, including:

• The type of collected personal information
• The purpose of information gathering
• Technology that is used during the process of information collection

As well, we fully comply with the General Data Protection Regulation protecting the privacy rights of EU residents and granting them their fundamental rights. About rights applicability see section II, “EEA users subsection” below.

We don’t directly interact with personal information holders during the process of information gathering and service delivery, for this we use a technology that gathers all essential data provided by our customers during “client-service” interaction process.

That’s why we highly recommend our clients to read the privacy policy thoroughly before starting using our service, so that in case of questions or concerns you could have an opportunity to address them beforehand.

AceeX SP.Z.O.O. is neither pursuing a particular data owner nor is interested in obtaining a certain type of user information, all information that is being collected is gathered solely for the sake of providing better service quality that is perfectly adjusted to the needs and demands of our clients.

In section II you will find the necessary information regarding services we provide to our customers and the number of cases your personal data could be collected for.

In section III you will find the relevant data types that might get retrieved whilst you stay on our website. We normally recommend our clients to browse through the official agreement before reading our Privacy Policies in order to clarify the most important collaboration details first.

Whilst utilizing our products, our clients and partners can apply cookies, tags, pixels or other technologies that belong to them and help them support necessary business activities.

Hence, we can not bear responsibility for such technologies, and all the consequences coming from their applications are subjected to their owners.

Same way, we can’t be held accountable for the privacy practices of our clients, our partners, and their other contractors, for we have no control over them.

If you have questions, comments, complaints or any important considerations regarding this version of the privacy policy you can contact our Data Protection Officer using the following e-mail: connect@aceex.io or contact AceeX SP.Z.O.O. by post:

AceeX SP.Z.O.O.
10018 54 W 40th St
New York, United States

Attn: Privacy Officer
connect@aceex.io

AceeX SP.Z.O.O. does not collect information that identifies visitors personally (your name, ID number, phone, etc.) and collects only information provided by visitors voluntarily. Such kind of information is used exclusively for the purposes described at the point of collection.

Your device type info, browser, and other types of pseudonymous data that doesn’t identify you personally belongs to the type of generalized information that is being collected on our website.

In case any kind of sensitive information from your website gets processed by our service during the technological process, it stays out of our sphere of control.

The type of data that we collect is classified as pseudonymous by the majority of jurisdictions, in particular contexts such user information as Internet Protocol (IP), or different unique device identifiers may be also gathered (e.g., for EU jurisdictions).

• Personal behavioral data regarding web resources of the client, web platforms used, website URL, domain name, time of visiting, number of pages viewed, keywords used for navigation, actions and performed on-site activities, banners and ads you click on, the type of platform, date and time stamps, exit and entrance pages, current geolocation (the geographical coordinates are auto-detected and may include your country, city, and zip-code).
• Browser-related information: languages and the browser you use, browser settings or history.
• Information describing the type of device you use: the model, year of launch, the country where the device was produced, OS, type of connection, IP identifier of your device.
• Information about your Internet provider (ISP) and service type details.
• A supplemental information such as statistical ID or advertising IDs that might be important in certain cases.
• Pseudonymous or general information that contains specific identifiers and is delivered by our clients or third parties. Interest-based information, mobile advertising ID, data segments from third-party data providers belong to this block as well.

For the sake of the relevance of service we provide for the publishers and advertisers, we use different data collection technologies typical for the ad tech industry. Such automatic data collection technologies are completely safe and secure, the data collected by them helps to deliver a particular advertisement to the target audience, narrowing up the targeting.
We collect information using:

Cookies. AceeX SP.Z.O.O. might use cookies for non-personal data collection through the user's web browser identification. Data collected through cookies is used to show the impression to the relevant user. A cookie is a small text file that is getting transferred on the user's hard drive while visiting a website and is stored on it temporarily or permanently. The cookie is linked to a web browser and is unique in every browser type. A cookie file does not contain a name, age, personal address, gender, phone number, email, or any other personal information of the user. We use cookies on our site to gather the preferences and stats in order to streamline the website browsing experience for every user and adjust browsing according to the user’s preferences.

HTML5 and Locally Stored Objects. Having the same core mechanism as cookies, the technology consists of code fragments that are also known as “locally stored objects.” HTML5 and Locally Stored Objects accumulate a greater span of data than cookies, however, when you clear your browser data this kind of information gets deleted along with your cookies. It works automatically, analyzing and gathering all the necessary information.

Tags and Pixels. Tiny, transparent pieces of code shaped as 1x1px images are used to track the user’s behavior on the Internet, our clients use them to gather behavioral information about the users as a part of an ad campaign. Tags, pixels or beacons are getting attached to the webpages of the site or inside the promo email to track the behavioral patterns of the user and subsequently use it for the analysis. Our system syncs both sources of information - the one gathered by our clients with data that belongs to us in order to verify its quality and serve the targeted ad to the end user.

Mobile Device Identifiers. Mobile IDs are used to find out how the inventory is performing during the retargeting campaign or measure the frequency in which a particular inventory has been shown to the particular user. The effectiveness of the advertisement and the quality of impressions can be greatly improved by transferring the ID back to the advertiser.

Software Development Kits. SDK is a specific set of code blocks developed in order to integrate the user tracking feature into the device directly. The user tracking feature may collect different kinds of information considering the user's mobile behavior and the process of utilizing the applications.

We save the right to collect, process, store or share identifiable or non-identifiable information in all ways and for all purposes that don’t interfere with laws.

In case we or our partners are involved in any kind of corporate transformations, such as merging, service transition to another provider, sale, reorganization or financial bankruptcy, the gathered information can also be subjected to transition or sale in the full accordance with current agreements and law.

The main goal of our service is to help our client to find the users for their advertisements by purchasing the relevant advertising inventory, for this our clients can use both types of user information, - the one accumulated by them and the one that clients receive during the process of our service delivery. As well, the process of data synchronization collected by the both parties (you and us) clears up and refines the inconsistencies and spots the core user’s interests that allows targeted advertisements to be more precise and effective due narrowing down the relevancy channel.

The user-data information that we collect can be used by us for such additional purposes as: running the customer analytics or customer research, generate ad performance reports, define overall trends for the service development, make the prognosis, run audit of the ad inventory and its quality according to the legitimate data usage purposes in US. We take every opportunity to improve our service and make it user-friendly as much as possible, that’s why we can involve user data information in the process of measuring the effectiveness and relate to this data for identifying the spheres for improvement.

Above-mentioned purposes let us aggregately share the user data with clients and partners, improve the algorithms of our service without affecting the user’s privacy or identifying them.
We also use the user data in order to protect the users from data leakages, and to block the fraudulent activities in our system.

If you are an EU citizen, the legal basis for using your personal data, according to GDPR, is subjected to particular circumstances in terms of data collection and processing procedures.

Thus, we are absolutely convinced that only your clear, informed data collection consent for processing can become a foundation for collecting and managing your data. We ensure that our clients are also operating in full compliance with GDPR and rely on the consent obtaining information from EU users.

The above-mentioned data protection regulations are extended on EU residents exclusively. In case you want to be consulted considering certain legal aspects of information management and collection please contact our Data Protection Officer via e-mail: connect@aceex.io

Please also note that you will have to provide us all necessary proofs testifying that you are EU resident therein being protected by current GDPR regulations, only this way we will be able to resolve your issue.

We respect the right of our customers to access and handle their user data the way they deem relevant, that’s why you can cancel your current consent any moment you need.

Please remember, in case your consent was given to our clients, you either need to ask for the consent withdrawal from them. If you provided a personal consent through the application, the latter should also have the in-built function allowing to turn the consent off, in such case return to the application and withdraw your consent through it directly.

In case you need to turn off personalized advertisement on your personal device, go to the settings and configure the feature by tuning “Limit AD Tracking” on your IOS device or choose “Opt out of Ads Personalization” on Android. Mind, this is not a current manual for your type of device, thus, you need to consult manufacturers in case you can’t find the updated info or manual considering consent withdrawal on your mobile phone, laptop, tablet, etc.

If your consent withdrawal procedure has been successful, you will no longer provide your personal data to us, all your user data will neither be collected, stored or processed by us (unless circumstances defined by regulation oblige us to keep that information). We will also do the utmost to erase your user information or to de-identify it with all possible means that our technology provides in case such information has been retained within the GDPR period.

Mind that if you decide to withdraw your consent from us, we will have to send further requests to our clients, who in respect of your decision must also quit using your personal information and stop targeting you as an audience.

Remember, in case of necessity, (to be compliant with GDPR or in our own interests)
we will still have to process your user data in spite of the fact that you called personal consent off or didn’t provide personalized ad consent in the first place.

We retain the right to process certain user information in case consent wasn’t granted, in case the legitimate interest enables. For each platform and service the legitimate interest will be defined separately on an ad hoc basis.

As an EU citizen, you have certain data privacy rights that are regulated by the GDPR data protection standards when it comes to your data collection and processing. You can find out about your current privacy rights in the GDPR, Chapter 3. If you consider some of those rights yet need to be executed, don’t hesitate to contact us, please don’t forget to bring the relevant proof that you belong to EU residents and thus can be subjected to such rights protection.

The source that obtains your personal information can only reach anonymous, impersonified data, it is impossible to recognize it individually or match it with you, that’s why you may have to provide some additional info to find out what information belongs to you (to fulfill your request), in some cases extracting such information might be limited by the technological processes.

Please take this into account. Our business is not geographically located in Europe and was not initially designed to correspond to the EEA aims. Please also be ready to familiarize yourself with the Section I that depicts the responsibility we take for our clients’ actions.

Please be aware, we will collect, store, and process your user data solely for the cases when it is necessary for the technological process, otherwise we erase the user data that is no longer relevant quarterly after the traffic analysis and inventory quality assessing.

In case your cookies are no longer serving the targeting process they are not processed by us, as well, on your device, the cookies expire the day they are due to.

We do not keep your information unless otherwise is required by the legislation or certain law regulations, taxing, and governmental financial entities. Same way, the courts of certain jurisdictions might oblige us to keep your user data in particular minor circumstances.

The information is shared with clients. With this function, the clients can buy ads and find the exact publishers they are looking for. In order to serve your relevant targeted ads, the clients utilize this information in combination with material collected on their side independently. With the help of your information, our clients may assess their own ad campaigns or digital inventory.

Access for governmental entities. In certain cases the user information might be shared with governmental entities such as courts, law enforcement, jurisdictions, emergency and security services in full accordance with current laws and regulations. The request for such information might be satisfied if the organization submitting such request belongs to the governmental organizations or is related to the law enforcement entities.

Side service providers. DSP typically collaborate with several SSPs, and in many cases with DMPs, as well, they may interact with a number of other platforms to ensure the smooth end effective bidding process. For the sake of convenience and safety these services also ally with certain third-party data specializing on information safety, technologies for analysis, and other companies that contribute to the smooth and secure service delivery.

Even though we know that targeted advertisements can be beneficial for both market participants - advertisers and customers, we honor the right and personal choice of every individual and enable you to turn off the function on any kind of device.

In order to turn off the feature, you will have to browse through your device settings. We feel obliged to warn you about the differences in current technologies, devices, and platforms.
Be aware, in case you decide to erase your cookies, it may also erase your targeted ad withdrawal or cookie blocks.

Please remember, in case your consent was given to our clients, you either need to ask for the consent withdrawal from them. If you provided a personal consent through the application, the latter should also have the in-built function allowing to turn the consent off, in such case return to the application and withdraw your consent through it directly.

In case you need to withdraw personalized advertisement on your personal device, go to the settings and configure the feature by tuning “Limit AD Tracking” on your IOS device or choosing “Opt out of Ads Personalization” on Android. Mind, this is not a current manual for your type of device, thus, you need to consult manufacturers in case you can’t find the relevant, updated information about consent withdrawal on your mobile phone, laptop, tablet, etc.

Despite the fact that every transmission carries a certain risk we make the utmost we can to offer our clients the safest ecosystem for their inventory monetization, successfully preventing various kinds of security issues.

We make sure to use the safest cutting-edge data protection technologies combined with strict organizational safety measures and procedures in order to avoid informational disclosures, prevent fraudulent activities, and guarantee relevance and accuracy of information for our clients.

Our technology corresponds to the best industry quality standards in terms of reliability, our administrative data safety practices guarantee safety of all personal information kinds that we collect or keep.

We don’t collect, process or store information coming from people under 18. If you noticed that your child submitted the user data without notifying you, please contact us so that we could resolve the issue. If you are underage, you can use our services under parental supervision.

In case you use this website, you accept these Privacy Policies automatically.

IF YOU REFUSE TO AGREE TO THE WHOLE NUMBER OF SECTIONS IN THIS PRIVACY POLICIES YOUR ACCESS TO THIS WEBSITE MAY BE RESTRICTED, WE HIGHLY RECOMMEND TO REGISTER AS AN ADVERTISER, PUBLISHER OR USE ANY PROMOTION.

Personally Identifiable Information is not the kind of information that is getting collected, processed or stored by our party.

The moment you browse our website it collects Non-Personally Identifiable Information automatically, by default, such data typically will include the browser type you are using, (IE, Chrome, Opera, Safari, Firefox, etc.) also your IP, website also scans the OS type installed on your PC (Windows, IOS, Ubuntu, etc.), and gathers the name of your Internet service provider.

Non-Personally Identifiable data is essential for streamlining and customizing your online experience, server problems investigations, and improving performance of the website. Aggregated statistics is another valuable thing that enables website usage analysis and audit. This Non-Personally Identifiable Information is not attached to personally identifiable information in any way.

Your IP address is a relative number that is automatically attributed to your device on the Internet and with the help of which the connection with the Internet is established.

The ad materials or inventory used by AceeX SP.Z.O.O. use your IP in order to facilitate the server problem diagnosing and improving the process of our site administration.

Your IP address will be associated with personally identifiable information only after you create your personal user account on AceeX SP.Z.O.O.

This website uses cookies. The cookie files that we use are not linked to personally identifiable information and are not matched to any type of other data that you submit via forms or questionnaires using the website.

We collect and store two types of cookies: Session cookies that streamline and customize your on-site user experience and facilitate the navigation process. They expire right after you close the website.

The persistent/long-term ones may be stored on your hard drive for an indefinite time period and cleared up manually by navigating your browser’s settings.

The person can’t use our services in case he or she hasn't reached the age of 18, as well, we don’t collect, process or store information coming from people under 18. If you noticed that your child submitted the user data without notifying you, please contact us so that we could resolve the issue. If you are underage, you can use our services under parental supervision.

Please note that you are fully responsible for the information you leave in the comments on our site. We cannot be held accountable for any kind of information you voluntarily place in comments on our website, either way, we are not in charge of your personal data placed in our comment section by other users.

Certain media widgets, including but not limited to: LinkedIn, Google+, Instagram, Telegram, Twitter, hyperlinks to FB, are regarded as third-party app providers. In the case when you need to erase your personal data contained in our blog section, you’ll have to channel the comment deletion request to the application directly. The order in which you interact with these social media tools, buttons, and tools is regulated by the privacy policies of their owners.

Summing up above-mentioned, - we are not eligible for managing your personal information placed by you or other people in the comment section of our website. Only your testimonials submitted to us directly can be regarded as a source of trustworthy and credible information that stays in our control. With your consent, username, and genuine feedback about our services, we will gladly arrange the placement of your testimonial on our website. In time when you decide to edit, rewrite or delete your comment, just leave your request by contacting us via email connect@aceex.io.