Privacy Policy

This Privacy Policy (“this Policy”) describes the privacy practices of Adprime Media, LLC (“Adprime”, “we”, “us” and “our”) for the information we collect through our websites, https:/adprime.com, https://thirdage.com and https://modernclinician.com (the “Sites”) and through our services as described below.  This Policy also discusses your rights and choices regarding the Personal Information we collect, how you can assert those rights, and how you can contact us to get answers to your questions.

Adprime and its affiliates operate advertising platforms, execute advertising campaigns, and provide related services from time to time (together with the Sites, our “Services”) that help publishers, advertisers, and agencies (collectively, our “Clients”) sell and purchase advertising space and identify audiences that may be interested in relevant products and services. We collect information, as described below, through our Sites and Services, and we collect other online and offline information about individuals’ interests and habits through web tracking technologies, and from our advertising partners, including data providers, ad exchanges, mobile app attribution companies, measurement companies, demand partners, and supply partners (collectively, our “Ad Partners”). We use collected information to create audience segments that we make available to our Clients to enable them to deliver targeted, interest-based advertising and to conduct analytics and research. Our Services deliver the targeted advertising messages to individuals on computers, mobile phones, connected televisions and similar devices and enables us to report back to our Clients about the effectiveness of their advertising campaigns.

You agree to let us collect and process your Personal Information as described in this Policy. Please read through this Policy in its entirety and understand its terms. We may update the Policy from time to time, so please check it occasionally.

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The following links will take you directly to the corresponding sections of this Policy:

  • Personal Information We Collect

  • How We Collect Your Personal Information

  • How We Use Your Personal Information

  • How We Share Your Personal Information

  • How We Protect Your Personal Information

  • Data Retention

  • Collection, Use, and Disclosure of Information by Others

  • Your Choices

  • Data Privacy Framework

  • European Privacy Rights

  • U.S. State Privacy Rights

  • California Privacy Rights

  • Nevada Privacy Rights

  • Texas Data Broker Notice

  • Cross-Border Data Transfers

  • Children’s Privacy

  • Changes to this Privacy Policy

  • Questions about this Privacy Policy

PERSONAL INFORMATION WE COLLECT

Adprime collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“Personal Information”). Adprime also collects non-Personal Information that cannot be linked or associated with any individual person or household. When non-Personal Information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information. We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:

  • Identifiers such as your first name, last name, alias, unique personal identifier, online identifiers (cookies, mobile advertising IDs, Device IDs), and/or National Provider Identifier (NPI) number.

  • Contact Information such as your practice address, mailing address, email address, and telephone numbers.

  • Sensitive Information such as your interest in receiving marketing material about a particular health condition.

  • Demographic Information such as age, gender, location and interests.

  • Financial Information from our Clients only, such as credit or debit card information, payment details, or other payment information.

  • Profile Data such as area of specialty, details about the content that you have consumed online and/or other details of digital properties that you have visited in the past, reading preferences, personal interests, feedback, and survey responses.

  • Healthcare Provider Information, such as publicly available information obtained from government databases and other sources.

  • Technical Information such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile carrier, and other technology on the devices you use while visiting any of our Sites, or viewing any of our Client’s ads or third party ads associated with our Services.

  • Geolocation Data, or other information that permits us to determine your location;

  • Mobile Device Information, such as the type and model, software version, manufacturer, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome or Safari), applications used and the version of such applications, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID.

  • Usage or Click Stream Data such as web pages which have been viewed, date and time, domain type, and responses by a web surfer to an advertisement delivered by us or a third party advertising technology vendor when you visit any of our Sites or view any of our Client’s ads, or third party ads associated with our Services.

  • Marketing and Communications Information such as marketing campaign data, click-through, your preferences and consent in receiving marketing from us and our third parties, email communications, and your communication preferences.

  • Inference Data including inferences drawn from the Personal Information identified above.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Information You Provide To Us:

Adprime may collect Personal Information from you that you voluntarily provide to us in various ways, including, but not limited to, when you:

  • Submit an inquiry or comment using our online contact form;

  • Contact us via email or through other Internet-enabled communications;

  • Respond to surveys or marketing communications;

  • Respond to promotions and sweepstakes offers through the Services;

  • Register on out Sites; and

  • Otherwise use or interact with our Sites.

Information We Automatically Collect From You:

Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us or our Sites and Services online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click rate data. When you access and use our Sites from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

Cookies and Tracking Technologies. We and our service providers use cookies, web beacons, pixels, and other tracking technology to recognize your browser or device and to capture and remember certain information about your activities on our Sites and through our Services. For example, cookies help us gather information about which pages you visit so that we can understand what web pages are of interest to users.

We use both session ID cookies and persistent cookies.  For the session ID cookie, the data is temporarily stored on your computer, but once you close your browser the cookie terminates.  A persistent cookie is a small text file stored on your hard drive for an extended period of time.  This allows us to track your activities while using the Sites or interacting with ads through our Services and help improve the functionality, navigation, and performance of the Sites. 

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features of the website may not function properly. You can manage your cookie preferences through your Internet browser. Modern browsers allow you to change your cookie settings. These settings are usually found in the “options” or “preferences” menu of your browser. You can find out more about cookies, including how to see what cookies have been set and how to manage and delete them, at http://www.allaboutcookies.org.  If you would like to opt-out of cookies, please see the Your Choices section below.

‍Please note that sometimes, the ads we deliver as part of our Services may include third party tracking technologies that we do not control, such as tags, pixels, cookies, etc. which may enable parties other than Adprime and its partners to collect data. These third parties most often are contracted by the advertiser or demand partner to measure performance of the advertisement, check for ad fraud, or some other purpose. We do not have control over those parties and their tracking technologies, and this Policy does not cover those technologies, the collection of data through them, or the use of that data by those third parties.

Log Data.  We receive information when an individual views content on, or otherwise interacts with, our Services, which we refer to as “Log Data.” For example, when an individual visits a website or the websites of our Clients, sees an advertisement delivered through our Services, or interacts with our email notifications, we may receive information about that individual. Such information includes Technical Information such as IP address, browser type, operating system, mobile carrier, device information (including device and application IDs); and Usage or Click Stream Data and Identifiers such as the referring web page, pages visited and cookie information; and Geolocation Data. We use the available Log Data to operate our Services and optimize the performance of our Services.

Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our visitors. These cookies collect Technical Information such as IP address; and Usage or Click Stream Data such as usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our Sites. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For information on how to opt-out from Google Analytics, click here. You may obtain additional information about Google Analytics by visiting the section titled "How Google uses information from sites or apps that use our services,” located at www.google.com/policies/privacy/partners/.

‘Do Not Track’ Browser Setting and Global Privacy Control. Certain web browsers allow you to turn on settings that automatically send a signal to companies you interact with online to indicate you would like to opt out of having your data shared or sold. Adprime has implemented and will honor opt-out preference signals like the Global Privacy Control (GPC). You can learn more about GPC  here. 

Cross-Device Matching. We may use your information to help us, or our third-party vendors, determine if you have interacted with the Services across multiple devices and to match such devices. To accomplish this, we may rely on information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, or we may use information we collect in conjunction with such third-party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated with each other, and may further provide services to our advertisers to better enable cross-device targeting and analysis. To opt-out of or restrict our use of certain cross-device data, please see the section titled Your Choices below.

Information We Collect From Third Parties

Our Sites may include links, plug-ins to websites operated by third parties, as well as embedded videos hosted by third party video management platforms. We may also collect Personal Information from various third parties, including those listed below. Adprime does not control any third party websites and is not responsible for any information they may collect. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user.  Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way that is different from this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

Our Clients, Ad Partners and Data Partners. Our Clients, Ad Partners, Data Partners may use or interact with our Services  and share the following information with us: Usage or Click Stream Data, including Identifiers such as browser cookie IDs, mobile device IDs third party IDs; Technical Information such as IP address, device type, operating system, hashed email address, or hashed mobile ID; Geolocation Data; Inference Data such as contextual information; and Demographic Information such as age and gender. Information we obtain from these third parties about an individual may be appended to information that we otherwise have for the purposes of targeting advertisements. For example, we match hashed versions of mobile IDs to data that are de-identified (made pseudonymous) about an individual that resides in our platform to target advertising to that individual based on their device activity, inferred interests, and location information.

In the process of serving an advertisement to a device, we, or our partners, may decide to serve an ad based on one or more audience segments associated with that device, and the audience segment we believe may be associated with that device. Where Adprime is able to use this and other information to infer that one browser or device likely belongs to the same user or household, the Services may consider those browsers and devices “linked” for purposes of ad serving and interest-based advertising.

Third parties may collect and use information about an individual’s activities, subject to their own privacy policies and terms. You should read all policies and terms on third party sites. Like many companies, we may allow cookie matching with select third parties. We only share pseudonymous information with such third parties that does not include an individual’s name, email address, or contact information.

Affiliates. Adprime is a subsidiary of Newsweek Publishing LLC (“Newsweek”). Newsweek and its affiliates may have access to information collected by Adprime, and Adprime may also have access to information collected by Newsweek.

Third Party Sources. We may collect Personal Information from third party advertisers who host and manage various online advertisements and ad platforms. We also may obtain Personal Information from governmental agencies or other publicly available sources.  Personal Information from these sources may be combined with Personal Information we collect from the other sources as described above, including analytics data.



HOW WE USE YOUR PERSONAL INFORMATION

Targeted Advertising. We use the Personal Information we acquire to better target advertising and to provide insights about an ad campaign. We may target advertising to the content of a page (known as “contextual” advertising), to an audience of people who enter a general location, to a group of people who may be most likely to be engaged by the particular ad as part of an interest-based segment of population, or to people who have engaged with a particular brand or content before (by something known as “retargeting”).

Advertising Insight and Performance. We may use Personal Information gathered from ads placed to provide our Clients with ad-related services, such as statistical reporting about website activity and the number of ads served, and to provide more ads to end-users based on the specific website URL, or webpage, visited. We may also disclose how frequently the average end user requests pages about a certain category (such as health or finance), or which ads segment of end-user interacts with on domains across the Services.

Performance of Services. In order to provide the services requested by our Clients and Ad Partners, we deliver ads on publishers’ pages and apps, create audiences for targeting, provide analyses of ad campaigns, limit the number of times a person sees the same ad, associate devices that may relate to each other, determine whether certain purchases are attributed to viewing a particular ad, and other ad reporting services.

Inferred Characteristics. When we collect data about consumers who interact with content, including interacting with ads, we may infer characteristics about those consumers. For instance, if a person consumes content about a particular health condition or topic, we may infer that the person is interested in learning about such condition or topic.

Fraud Detection and Security. We may use the data to protect the Services and our clients against fraud, as well as to protect the safety of the data we hold on our systems. We may be able to detect malicious or fraudulent activity through our services by using and reviewing the data.

Product Functionality and Improvement. We use the data to operate our services, for aggregate statistics, to improve our services and functionalities, and for other internal business purposes.

Communication and Legal Disclosures. We may use your information to respond to you if you reach out to us directly with questions or concerns; we may also disclose data to legal authorities or regulators if required by applicable law.

We reserve the right to supplement your Personal Information with information we gather from other sources which may include online and offline sources. We may collect information that is not personal information (“non-personal information”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal Information with Personal Information. If we combine any non-personal information with Personal Information, the combined information will be treated by us as Personal Information to the extent that it is capable of personally identifying you. We reserve the right to develop and derive aggregate data (meaning information that relates to a group or category of individuals, from which individual identities have been removed) from personal information in order to enhance and maintain the Services, and such aggregate data will be treated as non-personal information.

HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to using your Personal Information ourselves for the reasons stated above (and as otherwise mentioned in this Policy), we may share your Personal Information with other affiliates and entities as described below.

Personal Information You Instruct Us to Share. You may be presented with a survey, form, or another option through the Services where you may instruct us to disclose your Personal Information to certain third parties. If you choose to do so, we may disclose such Personal Information to third parties, including those as described in this section, and all such information will be subject to the third-party privacy policies and practices of such third parties.

Affiliates. We may share your Personal Information with our parent company, Newsweek, and other Newsweek affiliates from time to time.

Clients and Ad Partners. We provide Identifiers, Contact Information, Profile Data, Healthcare Provider Information, Technical Information, Demographic Information, and Usage or Click Stream Data to our Clients and Ad Partners so they may bid, purchase, and target ads directly or otherwise use or share that information with others for advertising or marketing purposes.

Other Business Partners. We may share aggregated or pseudonymous information (including demographic information) with partners, such as publishers, advertisers, measurement analytics, apps, or other companies. For example, we may tell an advertiser how its ads performed or report how many people installed an app after seeing a promotion.

We may also share Personal Information with third parties who enter into business relationships with us. These business partners may include direct marketers, publishers and unaffiliated third parties.

DMD Healthcare Communications NetworkSM. Adprime participates in the DMD Healthcare Communication NetworkSM (the “HCN”). The HCN is an allied community of medical publishers specifically servicing the information needs of US based healthcare professionals.  HCN implemented various technologies for universal registration/login among all Network member websites. These technologies are managed by DMD Marketing Corp. (“DMD”), and may involve the collection, receipt, and sharing of information with DMD, its clients and other Network members. If you would like to understand how Adprime’s participation in the HCN affects your privacy, please click here: http://usersupport.dmdconnects.com/PrivacyPolicy.htm. Please note that the HCN registration/login system may be different from the registration/login used by this digital service for other products and services. To the extent that anything in this privacy policy conflicts with the policy for the HCN, the conflict will be resolved in favor of the policy applicable to the HCN technologies.

Service Providers. We may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit. Business services provided include, but are not limited to, billing, advertisement delivery, data service providers, hosting services, communications services, website development services, payment processing services, compliance services, analytics services, and survey services.

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.

Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.


HOW WE PROTECT YOUR PERSONAL INFORMATION

We endeavor to incorporate reasonable safeguards to help protect and secure your Personal Information. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can however be guaranteed to be 100% secure.  Therefore, we cannot guarantee its absolute security. 

DATA RETENTION

Certain Personal Information we acquire through our Services is generally deleted within 100 days. Depending on the nature of the Personal Information we collect, we retain certain information in Adprime’s internal network where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your data, we will either delete or anonymize it or, if this is not possible (for example, because your data has been stored in backup archives), then we will securely store your data and isolate it from any further processing until deletion is possible.

COLLECTION, USE, AND DISCLOSURE OF INFORMATION BY OTHERS

This Policy applies only to information gathered by us in connection with the Services. There are other companies involved in collecting information and serving ads. The use of third-party pixels, cookies, and other technologies on websites that end-users visit, in apps that end-users use, and in ads served to end-users should be described by the privacy policies associated with those websites, apps, and ads. We have no responsibility for the collection, use, or disclosure of information by those third parties via such websites, apps, or ads.

YOUR CHOICES

Communications Preferences. We may send you marketing messages via email. If you receive a marketing message from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email), or by sending an unsubscribe request to us at privacy@adprime.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our services may no longer be available to you.

Targeted Advertising. Adprime and data providers we engage use cookies to enable you to receive customized ads, content or services, and to provide Adprime with certain information. To opt-out of these cookies, please visit http://optout.aboutads.info.  If you decide to opt-out, it will affect our ability to provide you with advertising content, and will prevent us from controlling the frequency with which you may view particular advertisements. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. In the event that we perform cross-device matching (as described above), once you have opted out on one device (“Opted-Out Device”), our third party partners will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes, or use data from another device for interest-based advertising purposes on the Opted-Out Device.

LiveRamp. We may share information that we collect from you, such as your IP address or other information about your browser or operating system with LiveRamp, Inc. LiveRamp returns an online identification code that we may store in our first-party cookie and it may be shared with Ad Partners to enable interest-based and targeted advertising. You may opt out of this use by visiting LiveRamp’s website  here.

Healthcare Providers. If you are a healthcare provider with a registered NPI number, you may request that your NPI number and other Personal Information be removed from Adprime’s NPI database at any time by submitting a request to privacy@adprime.com.

DATA PRIVACY FRAMEWORK

Adprime complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce.  Adprime has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles and the and the UK Extension thereto (“DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit Data Privacy Framework website.

The Federal Trade Commission has jurisdiction over Adprime’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

Data Transfers to Third Parties

We are responsible for the processing of Personal Information we receive under the DPF Principles and subsequently transfer to a third party acting as an agent on our behalf.  We shall remain liable under the DPF Principles if our agent processes such Personal Information in a manner inconsistent with the DPF Principles, unless we can provide that we are not responsible for the event giving rise to the damage. Be advised that we may be required to disclose your personal information in response to lawful requests by public authorities in the United States, including to meet national security or law enforcement requirements.

Your DPF Privacy Rights

You may have the right, under the DPF Principles, to access the Personal Information that we hold about you, and correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the DPF Principles, subject to certain exceptions. You may also have the right to opt out of having your Personal Information: (i) disclosed to a third party (other than parties that are acting as our agents to perform tasks on our behalf and under our instructions); or (ii) used for a purpose that is materially different from the purposes for which it was originally collected or which you subsequently authorized.

For more information about your DPF rights and/or to exercise such rights, please contact us at privacy@adprime.com.

Resolution of DPF Complaints

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Adprime commits to resolve DPF Principles-related complaints about our collection and use of your Personal Information.  EU and UK individuals with inquiries or complaints regarding our handling of Personal Information received in reliance on the DPF and the UK Extension to the EU-U.S. DPF should first contact us at privacy@adprime.com.

We commit to refer unresolved complaints to the Association of National Advertisers (“ANA”), which offers an alternative dispute resolution service for EU and UK and Gibraltar consumers and companies located in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://ana.net/dpf-consumers for more information or to file a complaint.  The ANA’s dispute resolution services are provided to you at no cost.

Under certain conditions, you have the option to invoke binding arbitration for complaints regarding DPF compliance that remain fully or partially unresolved. For more information about the terms under which we are obligated to arbitrate claims, please see Annex I to the DPF.

EUROPEAN PRIVACY RIGHTS

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Legal Basis

We will only use your personal data, as that term is defined under the General Data Protection Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where you have consented to a certain use of your personal data.

  • Where we need to comply with a legal or regulatory obligation.

Data Controller

Adprime is the data controller of all personal data collected through the Services. If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a complaint, please contact our privacy manager here: privacy@adprime.com.

Provision of personal data and failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Collection of personal data from third-party sources

We may obtain personal data and other information about you public sources and through our third-party partners who help us provide our products and services to you.

Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at privacy@adprime.com.

Data Transfers

We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at privacy@adprime.com.

Data Subject Rights

If you are situated in the European Union, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise your rights under the GDPR, please contact us at privacy@adprime.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

TCF Attestation

Adprime participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Adprime identification number within the framework is 623.

U.S. STATE PRIVACY RIGHTS

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, Minnesota, Tennessee, Maryland, or another U.S. state that has similar comprehensive privacy legislation (collectively, “Covered States”), you may have specific rights regarding your Personal Information under: the California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Texas Data Privacy and Security Act, Oregon Consumer Privacy Act, Montana Consumer Data Privacy Act, Iowa Consumer Data Protection Act, Delaware Personal Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Data Privacy Act, New Jersey Data Privacy Act, Minnesota Consumer Data Privacy Act, Tennessee Information Protection Act, Maryland Online Data Privacy Act, Indiana Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Rhode Island Data Transparency and Privacy Protection Act, and similar laws in other U.S. states (collectively, "State Privacy Laws"). This section describes the rights that consumers of Covered States have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are considered a consumer of Covered State and we are acting as a “controller” or “business” (as applicable) under State Privacy Laws with respect to your Personal Information.

Personal Information We Collect; How We Collect It; How We Use It

The following lists the categories of Personal Information that we may collect and/or have collected currently and during the preceding 12 months:

For Healthcare Providers: Identifiers, such as name, postal address, telephone number, email; Characteristics and Demographics, such as age and gender; Professional or employment-related information, such as current place of employment, specialty and NPI number; and all items collected below for consumers. 

For Consumers: Identifiers, such as cookies, mobile ad IDs, timestamps, user agent strings, unique personal identifiers, online identifiers, IP address; Geolocation Data; Internet and Electronic Network Information, such as information on a user’s interaction with a website, application or advertisement; and Inferences drawn from other Personal Information.

To see the sources from which we collect Personal Information, please see the section  How We Collect Your Personal Information above. Our business purpose for collecting such Personal Information is to provide the Services, including targeted advertising, and as further described in the section How We Use Your Personal Information above.

For the categories of third parties to whom we disclose such Personal Information, please see the section How We Share Your Personal  Information above.

As defined by State Privacy Laws, we “sell” or “share” certain data elements within the following categories of Personal Information: Identifiers; Geolocation Data; Internet and Electronic Network Information; Professional or employment-related information; and Inferences.

The third parties to whom we sell or share Personal Information include our Clients and Ad Partners.

Your Privacy Rights

In addition to the rights set forth in our Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:

  • Right to Know. You may have the right to know whether we process your Personal Information and to access such personal information. You may also have the right to request that we disclose certain information to you about our collection, use, or disclosure of your Personal Information. Delaware residents have the right to obtain a list of the of categories of third parties to which we have disclosed Personal Information, and Oregon residents may obtain a list of the specific third parties to which we have disclosed Personal Information.

  • Right to Data Portability. You may have the right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means.

  • Right to Delete. You may have the right to delete Personal Information that you have provided by or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in the State Privacy Laws.

  • Right to Correct. You may have the right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes for which we process it.

  • Right to Opt Out. You have the right to opt out of the processing of your Personal Information for purposes of: (i) targeted advertising; (ii) the sale of Personal Information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As of the latest date of this Policy:

    • We "sell" Personal Information, as "sale" is defined under State Privacy Laws.

    • We "share" (as that term is defined under State Privacy Laws) Personal Information for purposes of cross-context behavioral or targeted advertising.

    • We DO NOT engage in profiling decision based on your personal information that produce legal or similarly significant effects concerning you.

  • If you wish to opt out of the processing of your Personal Information for any of the above purposes, or opt back in, please visit the web page Your Privacy Choices https://www.adprime.com/data-privacy-request-1. For residents of California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, New Hampshire, New Jersey, and Oregon, or where otherwise required by State Privacy Laws, we will also treat opt-out preference signals as valid opt-out requests.

  • Right to Limit the Use of Your Sensitive Personal Information. If you are a California resident, you may have the right to limit the use or disclosure of your sensitive personal information (“SPI”). While we generally do not attempt to collect any SPI, we may be sent such information from publishers or other partners without prior notice. You can make a request for us to limit the use or disclosure of your SPI by visiting the web page Your Privacy Choices https://www.adprime.com/data-privacy-request-1. We will also treat opt-out preference signals as valid “Limit the Use” requests.

  • Right to Nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, we will not: (i) Deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights; Verifying Your Identity

To exercise any of your privacy rights, or if you have any questions about your privacy rights, you may contact us by:

Calling us at : 1(888) 546-8697 ;

Emailing us at privacy@adprime.com; or

Visiting the Your Privacy Choices https://www.adprime.com/data-privacy-request-1web page

After submitting a request, we will take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we will ask you to provide certain data points that we can seek to match with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.

Only you (or for California residents, an agent legally authorized to act on your behalf) may make a verifiable request related to your personal information. Certain State Privacy Laws also permit authorized agents to make an opt-out request on your behalf. If you are making a verifiable request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.

Response Time; Your Right to Appeal

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.

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CALIFORNIA PRIVACY RIGHTS

California residents can request a list of all the third parties to which we have disclosed certain personal information (as defined by California's Shine the Light law) during the preceding year for those third parties' direct marketing purposes. California residents may contact us using the information below or sending an email to privacy@adprime.com with the subject line "California Shine the Light Request", your name, a current California address including street address, city, state, and zip code, as well as sufficient information for us to determine if the law applies to you. You will need to attest to the fact that you are a California resident.

We will not accept requests by telephone, email, or facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.

NEVADA PRIVACY RIGHTS

If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information that we have collected (or may collect) from you to data brokers or other third parties. You can exercise this right by sending an email to privacy@adprime.com with the subject line “Nevada Do Not Sell Request.”

TEXAS DATA BROKER NOTICE

ADPRIME IS A DATA BROKER UNDER CHAPTER 509 OF THE TEXAS BUSINESS AND COMMERCE CODE. TO CONDUCT BUSINESS IN TEXAS, A DATA BROKER MUST REGISTER WITH THE TEXAS SECRETARY OF STATE (“TEXAS SOS”). YOU MAY SEARCH THE DATA BROKER REGISTRY ON THE TEXAS SOS WEBSITE TO IDENTIFY A SPECIFIC DATA BROKER AND VIEW ITS REGISTRATION INFORMATION.

CROSS-BORDER DATA TRANSFERS

Adprime provides the Services from the United States and operates under United States law. If you are located outside of the United States, the information we collect may be transferred to and processed in the United States and in other countries where the privacy laws may not be the same as the laws where you reside and, in some cases, may not be as protective. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers. 

CHILDREN’S PRIVACY

Our Services are intended for adult use only and are not directed towards children, minors, or anyone under the age of 18. If you are under the age of 18, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 18 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and to have this Personal Information deleted from our files.

CHANGES TO THIS PRIVACY POLICY

Adprime may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy. Your continued use of the Services following the posting of any changes to this Policy means you accept such changes. If we make a material change to this Policy or​ our privacy practices and believe that such changes will affect your Personal Information, we will take reasonable electronic measures to notify you of such changes and provide a reasonable opportunity for​ you to opt out of any further materially different collection, processing,​ or transfer of previously collected Personal Information under the changed policy. The process by which we notify you of material changes may include email or a pop-up notification on the Sites, depending on how you interact with us.

QUESTIONS ABOUT THIS POLICY

For questions or comments regarding our Policy, you should contact us by using the Contact Us form here. You can also email us at info at adprime dot com or write to us at:

Adprime Media, LLC

Attn: Privacy Team 
One World Trade Center 
New York, NY 10007

For more information about how users with disabilities can access this Policy in an alternative format, please Call 1(888) 546-8697.