------ Privacy Policy --------

AdSapiens Limited (“AdSapiens”) takes the responsibility of respecting and caring for your privacy seriously. This Privacy Policy lays out our protocols for data collection, protection and use. It will help you make informed decisions about your relationship with AdSapiens; please read it carefully.

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Introduction

Any reference to ‘us’, ‘our’, ‘we’ in this Privacy Notice is a reference to AdSapiens. We provide a creative solution for digital branded content (including video and non-video), facilitating the development, serving and distribution of digital display ads on the web or mobile environments and other digital devices and connected environments including computers.

AdSapiens offers its Services through secure email communications channels or via several platform-tools hosted under the adsapiens.com or futureadlabs.com subdomains referred to as our “Platform”.

Alongside our Sales, Account and Client Management Services, our Platform includes different modules used both by AdSapiens staff and/or Clients to manage campaigns end-to-end from initial procurement, production, optimisation, reporting and billing phases. Our Platforms are bespoke built to meet the needs of our Clients and internal teams in the delivery of mobile advertising campaigns.

The information we collect depends on what products or services you use and how you use them. This policy applies to:

"Visitors": Visitors of the AdSapiens website, all associated sites by AdSapiens, its subsidiaries, and affiliates, including AdSapiens sites around the world, and our creative platform, AdSapiens Direct (collectively, the "Site(s)"), who view only publicly available content.
"Platform Users": Users of our creative platform AdSapiens Direct, creative as a service, provided through our Sites.
"End Users": End-users of our digital advertisements created through and trafficked by AdSapiens products or services.
“Early Access Trial Users”: Invited end-users of our Alpha or Beta Platforms who will register and opt-in to a paid or non-paid contractual agreement and have early access to new tools, products, and services for feedback.

If you are applying for a role at AdSapiens please refer to our Candidate Privacy Notice.

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In using or accessing our Site or AdSapiens services (as defined in this Policy), you agree to our privacy policies outlined herein. AdSapiens will have the right to use your information as described in this Privacy Policy. If you do not agree to have your information used in any of the ways described in this Privacy Policy, you must discontinue the use of the AdSapiens Site or “Platform(s)” and any services provided by AdSapiens.

Our Privacy Policy will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.

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If you have any questions you can contact us at privacy@adsapiens.com.

This Privacy Policy will describe the data and information that AdSapiens may collect, process, use, disclose or retain about you or your device (computer or mobile, including tablet and mobile phone) when you visit our Site, use our Services or when you encounter Distributed Content served by AdSapiens at any Participant Site.

Participant Sites are operated and controlled by third parties, and the collection, processing, use, disclosure or retention of information by Participant Sites or other third parties working with such sites are governed by their privacy policies -- AdSapiens's Privacy Policy does not apply to such Participant Sites or third parties.

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Summary

This Privacy policy covers the following key subjects:

It explains how we use your information as a Visitor, Platform User and End User.
It aims to explain clearly what information we collect with your permission, what we do with it, and what we do not do with that information.
It holds us accountable for protecting your rights and privacy under this policy.

It also lays out in detail how you are consenting your information to be collected, processed and used, including:

The use of cookies and other tracking technologies like ‘Heat Mapping’
The transfer of your information outside your country of residence.
The transfer of your non-personal information between trusted partners and third-party entities as described in this policy, in order to fulfill a service as agreed by you, AdSapiens and/or such entities.
The collection, processing, use, disclosure and retention of your information by all entities as described in this policy, including AdSapiens as Data Controller and Data Processor (as applicable).

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Glossary of terms

For purposes of this policy:

"Personal Information" for non-residents of the European Economic Area means any information that can be used to identify, contact, or precisely locate a person, including name, email, address, and telephone number.
"Personal Information" for residents of the European Economic Area or United Kingdom means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This includes IP address and advertising ID (IDFA/AAID).
"Non-Personal Information" means information not included in the definition of Personal Information, such as pages or ads visited, time spent on pages, browser and device type, and referring and exit pages. For non-residents of the European Economic Area, IP addresses and advertising IDs (IDFA/AAID) are Non-Personal Information.

A list of additional terms for reference:

"Information" or "Data": Used interchangeably, "Information" or "Data" refers to personal and non-personal data that is collected, processed, used, distributed or retained from Visitors, Platform Users and/or End Users, by AdSapiens, to fulfil the terms of use of our Site or to fulfil our service agreements, as described in this Privacy Policy.
"Ad(s)" -- a digital advertisement or "adunit"
"Sensory ads" -- AdSapiens's user-engagement ad product, Sensory Ads are served on the premise that a user must voluntarily and actively participate in an ad experience by fulfilling a digital "gesture-based" (using the computer cursor, mobile touch-screen or mobile gyroscope type command) interaction. This means that a user must view and opt-in by engaging in order to benefit from the ad experience, as opposed to the traditional industry model of view-only.
"RTB" -- Real-time bidding refers to the buying and selling of online ad impressions through real-time auctions that occur in the time it takes a webpage to load.
"Bidder" -- AdSapiens is using a demand-side platform (DSP) to buy inventory required for serving adunits. The Trade Desk, Xandar & DV360 are companies that offer a "Bidder-as-a-Service" solution for programmatic RTB media buying.
"HTTPS" -- (HTTP Secure) is an adaptation of the Hypertext Transfer Protocol (HTTP) for secure communication over a computer network and is widely used on the Internet.
"Cookie" -- An HTTP cookie is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing.
"Beacons, Pixels" -- A Web beacon is an often-transparent graphic image, usually no larger than 1-pixel x 1-pixel, that is placed on a Web site or in an email that is used to monitor the behaviour of the user visiting the Web site or sending the email. It is often used in combination with cookies. AdSapiens uses third-party cookies provided by the DSP e.g. The Trade Desk, DV360 or Xandr. The AdSapiens site would also utilise cookies to conduct analytics. For more information please see our cookie policy.
"AWS" -- Amazon Web Services (AWS) is a subsidiary of Amazon.com that provides on-demand cloud computing platforms to individuals, companies and governments. "Amazon VPC" -- Amazon VPC lets you provision a logically isolated section of the Amazon Web Services (AWS) cloud where you can launch AWS resources in a virtual network defined by the client (AdSapiens).
"Amazon S3" -- Amazon Simple Storage Service is a web service offered by Amazon Web Services (AWS). Amazon S3 is a highly durable, highly available and secure object storage built to store and retrieve any amount of data on the Internet.
"AWS Kinesis" -- Amazon Kinesis Data Streams enables you to build custom applications that process or analyze streaming data for specialized needs.

1. What information we collect, how we do it and how we use it

In general, there are three categories of information we collect:

Information that you opt to share so we can use it to provide additional features and improve your experience.
Information that we must have for you to use the AdSapiens Platforms or Services.
Information collected from your interaction with AdSapiens Platform or Services as an End User of a mobile advertising campaign.

The kind of information we collect, and how we do it depends on which type of user category you fall into.

Contact information. When you request information about AdSapiens, via our Site's contact forms or through other means, register to use our Platform, or sign-up to our Platform or other services, you will be asked to provide certain Personal Information, which may include your name, email, mailing address, phone number, job title and name of your organisation.

When you voluntarily share Personal Information with us, this information is used by AdSapiens in a manner consistent with the permissions communicated to us. We may use this information to:

Respond to your specific query or request.
Communicate with you for marketing, research and promotional purposes.
Inform you of any training sessions or events.
Conduct communication relating to the service or project you signed up for.
Inform you of product and service updates.
Provide you access to the Platform or Service we provide.

You always have the option to opt out of marketing communications by unsubscribing, changing your user/profile settings on our Platforms or emailing us. You can also request that we delete your information at any time by contacting us directly at info@adsapiens.com or privacy@adsapiens.com.

We collect information from our Visitors via cookies or similar technologies, as laid out in our Cookies Policy.

In order to ensure the best user experience on our Sites, we may collect certain Visitor and browsing information from visitors to our Sites ("Visitor Analytics"). This may include IP address, browser and device type and language, referring and exit pages and URLs, date and time, amount of time spent on pages, what sections of the Site Visitors visit, and other, similar aggregate user data concerning your use of the Sites.

We may use this data to manage and improve our Site. In some areas of the world, certain Visitor Analytics may be Personal Information. Where this is the case, we comply with applicable laws regarding our use and processing of Personal Information.

Our Platforms are also likely to include ‘Heat Map’ tracking from services like HotJar or others which help us better understand your user journey. Please read the https://www.hotjar.com/privacy/gdpr-compliance/ about GDPR. If you are an “Early Access Trial” user and would like for your personally identifiable information to be removed from our Platform or ‘Heat Map’ profile, please email us at info@adsapiens.com or privacy@adsapiens.com

When you register or sign-up for our Platform or Services, we may request you to provide payment or invoicing information that may include invoicing contact (name, email, mailing address, phone number, etc.), credit card details (number, expiration date, security code), billing address, unique invoice identifier number, activation code, and similar information ("Billing Information").

AdSapiens uses this information for the purpose of invoicing and processing payments for services provided. We may use reliable third-party service providers to manage credit card processing. They are not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing. We may also use reliable third-party service providers to issue, manage and execute billing and payment events; they are not permitted to store, retain, or use Billing Information except for the sole purpose of performing the billing and payment service and are required to comply with applicable laws regarding our use and processing of Personal Information.

When you register or sign-up to our Platform, we request you to define a Platform User Profile that may include a username, contact email and user photo/avatar. This information will be visible to your project team members to enable communication and execution of the project.

You can edit and manage this information on your Platform account settings on our Platforms or by contacting us directly at info@adsapiens.com.

AdSapiens collects, processes, uses, discloses or retains information about End Users in their exposure or interaction with an ad. We may also collect information on behalf of our customers which may be a brand/advertiser, publisher, advertising agency and/or their agents, in the context of fulfilling our service to them.

Ad Serving Data includes standard digital advertising metrics as defined by industry bodies such as the Internet Advertising Bureau (IAB), including the number of ads viewed, time spent viewing an ad, page views, video views, number of ads clicked, IP address, device ID, GPS coordinates, advertising identifiers (IDFA/AAID). It may also include Personal Information that you actively choose to share with us through text field forms and other information about your interaction with the ads. We have integrated and worked within the Transparency and Consent Framework (TCF) v2.0TCF2.0 framework for all served display advertising.

End-User information may be used for lawful advertising purposes to provide you with a more tailored online advertising experience. AdSapiens may also use it to improve the functionality of our services.

In this context, AdSapiens may collect, process, uses, disclose or retain information about End Users in the following manners:

AdSapiens serves as a "Data Processor" in the context of user targeting and media buying in a programmatic environment. In contrast, the Bidder makes available information that is covered by consent passed on by the Bidder or Bidder suppliers.

AdSapiens may use Ad Serving Data to optimise the performance of the ad campaigns we are bidding for using a Real-Time Bidding Platform. For every relevant auction, we receive a bid request. This request is sent over HTTPS and is processed by our servers inside a protected AWS VPC. After we reply to the bid request, we delete the request data.

When we buy inventory using a Bidder, we receive logs with details about auctions we won. This data is sent to us using secure channels using tools like AWS S3 and AWS Kinesis. This data contains End User IP addresses, locations, browser details, websites name, app names, and all bid-related details, and we may use it for campaign optimization and reporting purposes. You can read more about the TCF2.0 framework

In addition to standard digital advertising metrics, AdSapiens also tracks "user engagements" that form the core offering of Sensory Ads.

Every time an ad is loaded in the user browser or app environment, AdSapiens tracks a set of events triggered by the engagement (including engagement gestures, clicks, skips, etc.). We send this data with actinoid back to our servers over the HTTPS channel.

AdSapiens may implement third-party performance tracking mechanism, such as click-through links and tracking pixels, per the request of our clients who receive and may share with us daily aggregated reports, used to monitor the performance of the campaigns.

These mechanisms may store the user's IP address, store a cookie in the user's browser and get information about the browser.

AdSapiens doesn't stream any cookies in End User browsers in the context of Ad serving. However, the Bidder (used to buy ad inventory) and its supplies may store cookies in the End User browser to profile inventory and to fulfill targeting requirements. For this use, AdSapiens does not target individual (identifiable) users. We only focus on the environmental variables like type of device, domain name and general geographical location of the user.

Third-party tools may also store cookies in the End User browser to help measure and monitor the ad campaign performance accurately. These cookies are governed by the third party and/or domain (publisher) terms.

To fulfill our service proposition, AdSapiens aggregates raw Bidder Data and AdSapiens Engagement Data for monitoring, optimisation and reporting purposes. Aggregation is usually executed in the form of daily sums and/or campaign lifecycle totals.

Aggregated reports are used to track the performance and delivery of campaigns and are shared with our clients (the advertiser) as part of our contractual obligations.

AdSapiens's customers and/or partners (collectively "Third Parties") may also use cookies to customize the End User's online advertising experience, based on the preferences or interests known or inferred from the information collected.

Our customers (the advertiser) may use cookies to serve relevant ads to you and help track results or measure the effectiveness of those ads. Third Parties may also combine information collected in the context of delivering an ad to you with other data they have independently collected over time across different online environments, including syncing or connecting behaviour across different websites, mobile apps or devices. These Third Parties collect and use information under their own privacy policies.

If you visit any of our offices or premises, we may have CCTV which may record your image.

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Storage of Ad Serving Data

Ad Serving Data is stored in AWS data centres in AWS North Virginia (USA) and the Republic of Ireland. There are two types of Ad Serving Data:

Raw Data -- Information we collect via The Trade Desk Bidder (containing the IP address, locations and details about the user browser) and tracking logs we store in encrypted S3 buckets with appropriate access control policies. We keep Raw Data for 90 days. This allows us to check and ensure that the relevant and subsequent aggregations are correct.

Aggregated Data -- Aggregated (non-identifiable) information is stored in secured and encrypted databases in the AWS data centres. At this stage we no longer store IP addresses, device IDs and locations we have received from the Bidder. We may store aggregated data indefinitely or as long as normal business operations will require. If you have any concerns about or would like to opt out of Ad Serving Data, you can contact AdSapiens at info@adsapiens.com. Opt-out: AdSapiens adheres to the DAA's Self-Regulatory Principles for Online Behavioral Advertising. To learn more about interest-based or online behavioural advertising, and other advertising companies' privacy practices and opt out from each or any of them (including AdSapiens), you may also go directly to the DAA website at http://www.aboutads.info/choices/.

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Sharing and disclosure of Personal Information

AdSapiens will only share Personal Information as agreed by the User at the time of collection, or in the following events.

We may share Ad Serving Dataas previously described..
We may share your information with reliable Third-Party Service Providers that support us in fulfilling our service obligations.
We may also share information with third parties that help us operate and market our services, per the situations described in section 1. We ensure that such third parties are contractually obligated to protect your Personal Information, as required by law.
Compliance with the Law. AdSapiens may disclose your information to courts, law enforcement, government authorities, or authorised third parties, if and to the extent we are required to do so by law or in a good-faith belief that such action is necessary or advisable to comply with any laws of any country or region which may assert jurisdiction) or to respond to a judicial or other governmental action, order, subpoena, request, demand or warrant. We may make such disclosures without providing notice to you.
Against Liability or Fraud. We reserve the right to disclose one or more clients' and/or individual users' information if it is appropriate or necessary in AdSapiens's discretion to: take precautions against liability; protect against fraudulent, abusive, or unlawful uses; investigate or defend against any third-party actions or allegations (including assisting a client or third party to do so); assist government enforcement agencies; or protect the security, integrity, rights, property, or personal safety of AdSapiens, its systems and services, as well as its employees, clients or others.
Business Transfers. If AdSapiens undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.
AdSapiens may also disclose your information under circumstances not mentioned above, with the prior consent of the entity or third-party that submitted the information to us.

Transfer of information across regional/national borders

AdSapiens is a global company. Our Servers are located in the US and in the Republic of Ireland. Any information collected and provided to us, including Personal Information, will be transferred to, and will be processed through, our servers in the US and/or the Republic of Ireland.

By accepting our Terms of Use, you are consenting to the transfer of data to and processing of data, from your country of residence to the location of our servers. If you do not consent to this, do not submit Personal Information to AdSapiens, or contact AdSapiens to correct or delete your Personal Information via info@adsapiens.com or privacy@adsapiens.com.

AdSapiens endeavours to ensure appropriate safeguards are in place requiring that Personal Data will remain protected. We use Standard Contractual Clauses with entities who We share Personal Data with outside of the EU or UK.

EU and UK General Data Protection Regulation (GDPR)

AdSapiens is committed to compliance with the GDPR, which went into effect in May 2018. If you are a resident of the European Union or United Kingdom you have the following rights:

The right to request access to, or ask us to provide you with copies of, Personal Data that we hold about you at any time.. If AdSapiens is the Data Controller with respect to your data, we will respond to your request within a reasonable period, and if we are the Data Processor with respect to your data, we may redirect your request to our customer acting as the Data Controller with respect to your data. We may decline a request for access to Personal Data in circumstances prescribed by relevant privacy laws. If we decline a request, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.
The right to ask us to delete any Personal Data that we hold about you free of charge, unless we are required to maintain a copy of this data pursuant to applicable law.
The right to ask us to update and correct any out-of-date or incorrect or inaccurate Personal Data that we hold about you free of charge. We will take reasonable steps to correct the information so that it is accurate, complete and up to date. If we refuse to correct your Personal Data, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint
The right to opt-out of any marketing communications that we (or any third party to whom we have disclosed your Personal Data with your consent) may send you or to withdraw your prior consent or object to any further processing of your Personal Data.
The right to request information about any automated decisions made using your data have legal consequences for you or significantly affects you.
The right to lodge a complaint with your local Data Protection Authority concerning AdSapiens's processing of your Personal Data.

If you wish to exercise any of the above rights, send us an email at privacy@adsapiens.com. Before we process any request, we may ask you for specific Personal Data to verify your identity, and in situations where AdSapiens is the Data Processor, consult with the Data Controller of your data. Where permitted by local law, we may reject requests that are unreasonable or impractical. Please allow us a reasonable time to respond to your inquiries and requests.

If you are not satisfied with our response, or believe we are processing your personal data not in accordance with the law, data subjects have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work, or place of the alleged infringement.

If you are located in California

This section only applies to Our processing of Personal Data as a “business” under the California Consumer Privacy Act (CCPA).

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The CCPA provides California residents with the right to know what categories of personal data AdSapiens has collected about them and whether AdSapiens disclosed that Personal Data for a business purpose (e.g. to a service provider) in the preceding 12 months.

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If You are a California resident and would like to exercise any of Your rights under the CCPA, please contact info@adsapiens.com or privacy@adsapiens.com. We will process Your request in accordance with the Applicable Laws.

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Sales of Personal Information Under the CCPA.

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For purposes of the CCPA, AdSapiens does not “sell” Personal Data, nor do We have actual knowledge of any “sale” of Personal Data of minors under 16 years of age.

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Non-Discrimination. California residents will have the right to exercise the rights conferred to them by the CCPA.

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Authorised Agent. Only You, or someone legally authorised to act on Your behalf, may make a verifiable consumer request under the CCPA. If applicable, You may also make a verifiable consumer request on behalf of Your minor child. To designate an authorised agent, please contact Us at privacy@adsapiens.com.

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Verification. To protect Your privacy, We will take steps to verify Your identity before fulfilling any consumer request under the CCPA. When You make a request, We will ask You to provide sufficient information that allows Us to reasonably verify You are the person We collected Personal Data about or an authorized representative, which may include Your email address.

If You are located in Brazil…

This section only applies to Our processing of Personal Data under the Brazilian Lei Geral de Proteção de Dados (LGPD).

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In addition to the rights described above, You also have the right to:

access Your Personal Data processed by AdSapiens;
unless restricted by law, request information about the public and private entities with which We have shared Your Personal Data;
oppose to the processing carried out; and/or
receive information about the possibility of not providing Your consent and the consequences of such denial.

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If You are a Brazilian resident or were in Brazil when Your Personal Data was collected and would like to exercise any of Your rights under the LGPD, please contact Us at privacy@adsapiens.com.. We will process Your request in accordance with the Applicable Laws.

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Subject Access Request as a Service (SARaaS)

We are committed to providing the information you request as part of your Subject Access Request and have procedures in place to ensure this occurs in a timely fashion.

We do not have agreements in place with any third-party platforms that offer “Subject Access Requests as a Service”. As a responsible data controller of your personal information, this represents significant risks when sharing data. The right of access afforded to you, does not obligate data controllers to share data with 3rd parties. It is our policy to provide the information directly to data subjects ensuring the safety and security of the information throughout the process.

We will monitor future guidance from the Information Commissioner’s Office but currently, undertake our own reasonable measures to verify the identity of data subjects. We would like to assure you that the protection of your data is our main concern and we are committed to providing information as part of any valid request.

Sharing and Social Media Features

AdSapiens works with social media tools, services and networks, such as LinkedIn, Facebook and Twitter. We provide users with both proprietary and branded tools to enable them to share an item of Distributed Content, solicit or refer other users to view Distributed Content or express or broadcast their opinion about an item of Distributed Content.

In some cases, using these tools will require a user to provide personally identifiable information. For example, a user may send a link for certain content to one or more recipients by email with a personal message.

AdSapiens does not use the email addresses, except as necessary to deliver the communication as requested, and does not store the email addresses. If you use a tag, button or sharing feature that is provided by a branded third-party social media service or network, such as a "Like" button, you may be required to log-in to your account or otherwise take steps to access such third party services. Such collection use and disclosure of any information by or in relation to such third-party service is subject to its privacy policy, and this Privacy Policy does not apply.

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Security of your Personal Data

AdSapiens adheres to reasonable technical and organisational security protocols to safeguard Personal Data submitted to us via our Site or Services, according to the voluntary principles of information sharing outlined in this document.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot control the actions of third parties with whom you elect to share your personal data. We cannot assume responsibility or liability for the disclosure of your information due to errors in transmission, unauthorised third-party access, or other causes beyond AdSapiens's reasonable control. We cannot guarantee that only authorised persons will view your Personal Data.

Children's Privacy

AdSapiens adheres to strict protocols to safeguard children's privacy. We do not knowingly collect Personal Data from any child under 16 years of age without consent or authorisation of the holder of parental responsibility for said child. If you are under 16 years of age, do not use our Services and do not provide any Personal Data to us. If you are a parent of a child under 16 years of age and become aware that your child has provided Personal Data to AdSapiens without your consent, please contact us at info@adsapiens.com or privacy@adsapiens.com.

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Changes to the Privacy Policy

AdSapiens may update this Privacy Policy from time to time, so you should review this Policy periodically. We'll notify you of material changes to the Privacy Policy via a notice on our Site(s) and/or a direct communication (i.e. via email). When appropriate and required, we may notify you and request continued acceptance of the revised Terms of Use and/or Privacy Policy. You may be provided other privacy-related information in connection with your use of offerings from AdSapiens and for special features and services not described in this Privacy Policy that may be introduced in the future.

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Contact Information

If you have questions or concerns regarding this Privacy Policy, including our policies for the collection, processing, use, disclosure or retention of information and/or our use of cookies, you can contact us here:

privacy@adsapiens.com

AdSapiens Limited

10c Warner Street,

London,

EC1R 5HA,

United Kingdom

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For EEA residents: Please contact our EU Representative at eurep@adsapiens.com

Alternatively, they can be reached by post or phone:

The DPO Centre

Alexandra House

3 Ballsbridge Park

Dublin

D04C 7H2

(+353 1 631 9460)