I. Privacy notice
1. AdAsia Holdings Pte. Ltd. (“AdAsia”, “us”, “we”, or “our”) operates an advertising marketplace (known as the AdAsia Premium Marketplace) that provides advertising solutions to advertisers and publishers from the Asia-Pacific region (“APAC”). These advertising solutions range from the static display of content through banners on our publishers’ websites to video advertisement displayed on these websites (“Ad and Video Network Service”).
2. Through our AdAsia Premium Marketplace, website publishers are able to monetise their website traffic effectively by tapping onto the combined demand from AdAsia and third-party sources.
(a) Publishers within the AdAsia Premium Marketplace are also required to abide by the AdAsia Digital Platform Terms of Service
II. What information do we collect?
6. We may collect the information listed below about your activities when you visit our publishers’ websites and use our Ad and Video Network Service (“Activities Information”).
7. This is mainly to allow us to provide more relevant advertisements to you, or to produce advertising reports to our customers. These purposes are described below in Section V below.
8. Browser/Technical information. We may collect non-personally identifiable information that your browser automatically sends to us when you are visiting a publishers’ website and using our Ad and Video Network Service, such as:
(a) Page URL;
(b) Information regarding the browser such as the type and version of the browser;
(c) Type of device and operating system used;
(d) Network carrier information;
(e) Non-precise location information (limited to the country and city);
(f) Mobile application information; and
(g) User interactions with the Ads, such as clicks or video views.
9. IP Addresses. An IP address is a unique address that your computing device(s) may use to identify itself and communicate with other devices in the IP network. This may allow us to determine the rough geographical location (limited to country or city) of the user. We do not, however, actively seek to identify you from the IP address information collected, nor do we link personal information (if any) with IP addresses to identify individual(s). Also, while we may process this information, we do not store your IP Addresses.
10. Usage of video and related information. We deliver our advertiser client’s video advertisements through the use of a third-party video player hosted or embedded in the advertising unit or space on the publishers’ websites. Through such third-party video player(s), we may collect information of the user’s usage and interactions with the video advertisement, such as the duration that the video was played, video size when played, and whether the user clicked onto the hyperlinks in the video provided.
11. We do not collect any information which will enable us to identify you when you click on advertisements on our publishers’ websites or on our Ad and Video Network Service.
Limited personal data
12. We may additionally from time to time collect your personal data to support the delivery of our Ad and Network Service or for advertising campaigns (“Personal Data”). Such information is listed below.
14. Advertising Campaigns. In some instances, our advertiser clients may ask us to run advertising campaigns which, as part of the promotion or services offered, may require the participant or user to provide his or her personal data. Where a participant or user voluntarily provides his or her personal data to AdAsia, AdAsia shall be entitled to collect, process, store and disclose such personal data for and on behalf of its client for the purposes for which it was collected. However, AdAsia’s client remains primarily responsible at all times for the collection, use and disclosure of the personal data.
15. Other types of collection of personally-identifiable information. We generally do not collect personally-identifiable information that do not fall within the two categories mentioned above. In the instance where we collect your personal data, it is on a voluntary basis and we will obtain your consent.
III. How do we collect information?
16. We use a variety of technologies to collect and use the Activities Information.
(a) Web tags: Our web tags collect information from your browser when you visit our publishers’ websites, including information regarding the browser, device information, and click stream information. Such information is then transmitted to us via the web tags.
(b) Cookies: A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies are sent to your browser from a website and stored on your computer's hard drive upon your consent. Cookies transmit information about your preferences and history such as your browser type, search preferences, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. It does not contain any data that will allow us to determine your actual identity.
(c) Pixels: A pixel is a microscopic graphic image embedded on a webpage. It collects information regarding the use of the webpage containing the pixel.
17. In respect of the Personal Data that we may collect, we collect such personal data directly from you or your authorised representatives.
IV. How do we use information collected?
18. We collect the Activities Information to enable us to:
(a) Make online advertisements relevant to you;
(b) Monitor, assess and track the success of advertising campaigns;
(c) Provide reports and analysis to allow our network of publishers and advertisers to understand the performance of the advertisements that are being displayed;
(d) Understand trends and your needs;
(e) Improve your experience across multiple browsers and devices (such as smartphones, tablets, computers, etc); and
19. We, however, do not seek to identify you through such Activities Information. Instead, we treat the Activities Information as aggregate data for the purposes we mentioned.
Limited personal data
20. We will use your Personal Data for the purposes in which it was collected. If we intend to use your Personal Data for a materially different purpose, we will inform you accordingly.
V. Does AdAsia share data with third-parties?
A. AnyMind Group
21. We may disclose the Activities Information and Personal Data to any member of our group of companies, including our subsidiaries, ultimate holding company and all its subsidiaries, insofar as reasonably necessary for the purposes, and on the legal bases set out in this policy. Information about our group of companies can be found here
B. Third-party service providers
22. We may employ or engage third-party service providers or third-party technology providers to provide us with ad campaign or site analytics, ad verification data, aggregate data of users, hosting services, and other similar technology or services for our Ad and Video Network Service. In order for these third parties to provide us with such technology or services, we may share Activities Information with them.
23. These third parties have access to the Activities Information only to perform the tasks stated in this Policy. We do not provide these third parties with personal data.
C. International transfers
24. We may transfer to and maintain on computers located outside of your state, province, country or other governmental jurisdiction the Activities Information and Personal Data where the data protection laws may differ from those in your jurisdiction.
26. The security of your data is important to us, but remember, no security or storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.
D. Compliance with legal obligation
27. AdAsia may be required to disclose your information or other information collected by us in order to comply with the law and other legal obligations. Under these circumstances, AdAsia will disclose the requested information. However, we will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
VI. Links to third-party sites
VII. Security of information collected
29. We regard breaches of your privacy and information breaches very seriously and have put in place reasonable security measures to protect the information it collects. These measures include the training of employees on good data protection practices and confidentiality; dealing with personal data on a need to know basis; and securing personal data against misuse, loss, unauthorised access, modification or disclosure.
30. Notwithstanding the measures and steps taken by AdAsia to protect the information it collects, you will appreciate that we cannot guarantee its absolute security. This is especially so in respect of cyber-attacks, spy-ware, hacking and viruses. Accordingly, you will not hold us liable for any unauthorised access, modification, destruction or disclosure arising from such risks.
VIII. Accuracy of information
31. It is our responsibility to ensure that your personal data in our possession is accurate. AdAsia will take reasonable steps to ensure that the personal data which is inaccurate will be rectified without delay.
32. If you wish to update your personal data we hold about you, please submit your written request to our data protection officer at the contact details below. We may require you to verify your identity.
IX. Retention of information collected
33. AdAsia will not retain the Activities Information or Personal Data (or any documents or records containing personal data, electronic or otherwise) for any period of time longer than is necessary to serve the purposes for which it was collected, or as required or permitted by applicable laws.
34. AdAsia will cease to retain the Activities Information or Personal Data or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the information was collected, and is no longer necessary for legal or business purposes.
X. Right to access personal data
35. You may seek access to amend, correct inaccurate or delete your personal data held by us.
36. To make a request to access the personal data we hold about you, please make a written request to the personal data protection officer at the contact details provided below. We will require you to verify your identity and to specify what personal data you require.
37. We will endeavour to respond with a reasonable amount of time.
XI. Opting out
38. You are allowed to withdraw consent to the collection, use and disclosure of your personal data at any time. You may withdraw your consent by submitting a written request to our personal data protection officer at the contact details below. Upon receipt of request, we would require reasonable time for your request to be processed and for us to notify you of the consequences for the withdrawal of consent. Depending on the nature and scope of the request to withdraw, we may not be able to continue providing our products or services to you.
39. Our primary ad-serving service providers also provide options to opt out of their services. The instructions to opt out may be found in their privacy notices found below:
(b) SMART: http://www.smartadserver.com/diffx/optout/IABOptout.aspx
(c) Google: https://adssettings.google.com/
40. Please note that the above links may not be up to date, and you would be advised to check for the most up-to-date link.
41. In the event you have chosen to opt-out but use a different computer, browser or mobile device, you may have to renew your choice to opt-out.
XII. Other important information
No solicitation of business or consumers from European Union
42. We do not actively or intentionally solicit businesses or consumers in the European Union (“EU”).
43. Our publishers and advertiser clients are required to ensure that they do not send, transmit or forward any personal data or non-personally identifiable information from the EU or relating to EU citizens to us. If there is a need to provide us with such information, they will have to provide us with reason(s) beforehand for our assessment.
44. AdAsia does not create segments that target children below the age of 16 years old. It is not AdAsia’s intention to collect or process data from any child below the age of 16 years of age, except with the consent or authorisation of the parent or guardian of the child.
XIV. Contact us
Last updated: 25 May 2018