In the course of our business, ad pepper media USA (“ad pepper”) collects, uses and discloses personal data on a large scale.  We collect, use and disclose personal data through Internet advertisements, surveys, etc. subject to contracts with our third-party business and advertising clients.

ad pepper wants our users to have confidence in our online services.  To help users understand our collection, processing and use of personal data, we provide the following information:

1. The Data We Collect, and How We Collect It. 
Personal data is data concerning the personal or material circumstances of an identified or identifiable individual, such as name, address, age, e-mail address, telephone number or information on specific preferences, likes etc.  We collect personal data that is submitted to us by users who click on or access the Internet ads, surveys, etc. that we make available.  Sometimes we obtain personal data from third party sources (such as the purchase of mailing lists, etc.). We only obtain such data where the third party assures us that it has obtained the prior approval of individuals to disclose their personal data to recipients such as ad pepper media. Usually, such data is used by our mailpepper program to contact individuals who participate in our opt-in advertising preferences program (see No. 5, below). 

2. Many Ads Are Served With No Collection of Personal Data. 
In simple advertising contacts with the user (e. g. serving pop-up ads on a website), ad pepper does not collect or process any personal data. Only non-personal data is used to serve ads, such as information on the server the user has used to access the Internet, the user’s browser type and whether the user clicks on an ad.   All this data is recorded anonymously.  ad pepper media cannot use such information to identify a particular individual.

3. All Personal Data Is Provided By The User.  
ad pepper media collects and processes personal data through various means of advertising (e.g., pop-ups, pop-unders, and banner ads). The extent and the kind of personal data we collect depends on the information that users transmit by filling in input fields when users click on the ads, surveys, etc. that we present.

In many cases, ad pepper media relies on a “confirmed opt-in” solution: when a user submits his/her personal data, ad pepper sends the user an e-mail confirming that the user’s information has been received. These confirmation e-mails direct users to contact ad pepper if someone else has submitted the user’s personal data without his/her permission, or if the user wishes to be removed from ad pepper’s database.  In this way, ad pepper media helps to ensure that the user (and not a third party) has entered his/her own data and has granted ad pepper media the permission to use it.  ad pepper media believes these steps demonstrate our respect for our user’s right to determine how their personal data is used. 

The user can withdraw consent for ad pepper’s use of his/her personal data at any time by contacting ad pepper or following the instructions included in any confirmation e-mail sent to the user.

4. How Personal Data Is Used And Shared With Third Parties. 
ad pepper collects most personal data on behalf of third party businesses (e. g. websites, advertising customers, and agencies).  In such cases, ad pepper’s role is simply to serve Internet ads and surveys and to collect and assemble personal data that is submitted by users.  When the data has been collected, ad pepper turns the data over to the third party for which it has been collected and has no further control over the use or disclosure of that data. 

In some cases, however, ad pepper collects personal data on behalf of a third party, but retains a copy of that data, which is added to ad pepper’s database of contacts.  In these cases, ad pepper has no control over the use and disclosure of personal data by such third parties, but it will administer the personal data it retains in accordance with this privacy policy.

The purposes for which ad pepper or our third-party clients collect personal data are mainly marketing-oriented and include, among other things, market research, the soliciting of customers, product information, service development, generating addresses for a newsletter subscription, orders, etc. 

When personal data is collected by ad pepper on behalf of a third party, the identity of the third party will be identifiable within the context of the ad or information presented to the user. In such cases, the privacy policies of the third party apply to the collection, use and disclosure of such personal data—users should review the applicable privacy policy of such third parties.  In most cases, these privacy policies will be available via a link included in the ad or survey.

It is important that all users understand that this privacy policy only addresses how personal data will be collected, used and disclosed by ad pepper; it does not address how such data will be used or disclosed by third parties.  When ad pepper provides personal data to the third party is responsible for compliance with applicable privacy laws. In such cases, this policy does not apply and ad pepper media disclaims any liability to the individual who provides their personal data. Ad pepper media cannot exercise any influence on such third parties, other than obtaining the written commitments of the third parties to comply with laws applicable to them. ad pepper media is bound by the instructions of the third parties with whom we have contracted to collect and disclose personal data.

5. mailpepper.
Where ad pepper retains a copy of the personal data it has collected, such data will usually be made available to the mailpepper program. mailpepper may use this data to contact individuals seeking participation in our opt-in advertising preferences program.  mailpepper also distributes advertisements and other content from third parties to individuals in the mailpepper database.  In either case, individuals may have their contact information deleted from the mailpepper database by following the directions for unsubscribing included in any e-mails sent by mailpepper.

6. Personal Data Provided For Specific Purposes Will Be Used For Those Purposes. When a user provides personal data for specific purposes (for example when requesting a newsletter), ad pepper will process and use such data to satisfy the user’s request, and only to the extent necessary for this purpose.  ad pepper limits any other collection, use or disclosure of personal data to the extent of any express consent provided by users.

7. We Use Cookies, But Users Control Them.  
ad pepper uses cookies to optimize the use of the Internet for users by reducing the repetition of advertising. No personal data is collected by means of ad pepper’s cookies. The use of cookies, however, is not indispensable to ad pepper. Therefore, the user can deactivate the cookie function at any time by changing the preferences of his/her Internet browser.

8. We Employ Information Security.  
ad pepper uses physical, technical and organizational measures to help ensure the confidentiality and integrity of the personal data we maintain—in particular to protect such data from unauthorized access. Access to all ad pepper data-processing programs and facilities is restricted with password protection; these facilities also employ encryption technology.  The employees of ad pepper are obligated to preserve confidentiality and data protection. Employees may only process and use personal data for the purposes and to the extent that the user has given his/her consent and within the scope of their daily work related to the fulfillment of these purposes.

Any third-party business to which ad pepper provides personal data will maintain such data in accordance with its own information security policies and procedures.  ad pepper has no control over such third parties, other than our service providers, with regard to information security.

9. Use of Service Providers.   
When ad pepper uses external servers or service providers for the storage or processing of user data, we seek assurances from such service providers that they will observe at least the same data protection standards as ad pepper does.

10. Data Destroyed After Use. 
Personal data that is no longer needed for the purposes for which it was provided to ad pepper and/or for the use of which consent has been revoked by the user, will be permanently destroyed. 

11. Users’ Rights.  
The user is entitled to access information on the stored data relating to the user from ad pepper media or their service providers, to revoke consent for the use of personal data, and to have such data deleted.  ad pepper can only provide access to personal data, affect the use of personal data, or delete personal data that is in our possession.  If personal data have already been disclosed to a third party with whom we have contracted, we have no ability to prevent the future use of such data or to delete it.

12. Contact Us. 
If you have any questions concerning our Data Privacy Policy, or if you want to exercise your right to access data, revoke your prior consent to our use of such data, or have such data deleted, please do not hesitate to contact us at: dataprivacy@adpepper.com.

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