Privacy Policy

Last Updated: 23.12.2024

Welcome to ADA Media Limited DBA UpAds ("us", "we", or "our"). We are committed to protecting your privacy and maintaining the security of any personal information received from you. This Privacy Policy outlines our practices concerning the collection, use, and disclosure of user behavior data, including data collected through Google Analytics, when you visit and interact with our website.

Information We Collect

We may collect non-personal information about your interactions with our website through the use of Google Analytics and similar tools. This information may include:

  1. Device Information: We may collect information about the devices you use to access our website, such as IP addresses, browser types, operating systems, and other technical information. This data is collected in an aggregated and anonymized form and cannot be used to identify you personally.
  2. Usage Data: We may gather information about your interactions with our website, such as the pages you visit, the links you click on, the time spent on each page, and other similar interactions. This data is collected in an aggregated and anonymized form.

Use of Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc. ("Google"), to collect and analyze non-personal information about your use of our website. Google Analytics uses cookies and similar technologies to collect and store information about your interactions with our website. This information is used to analyze user behavior and improve the functionality and content of our website.

For more information about Google Analytics and how it collects and processes data, please review Google's Privacy Policy: https://policies.google.com/privacy?hl=en-US.

Data Sharing and Disclosure

The user behavior data we collect through Google Analytics is used solely for the purpose of improving our website and enhancing user experience. We do not share, sell, or disclose this data to third parties, except as required by law or in connection with the operation of our website.

Data Retention

We retain the non-personal user behavior data collected through Google Analytics for as long as necessary to fulfill the purposes outlined in this Privacy Policy. This data is periodically purged to ensure that we do not retain any unnecessary or outdated information.

Supplemental U.S. state specific privacy rights and disclosures

This section applies only to Personal Information collected about consumers residing in the United States. Depending on the state in which you reside and the way in which you interact with us and our Services, you may be entitled to additional disclosures regarding the Personal Information we collect about you. You also may have certain rights regarding that Personal Information.

Personal Information we have collected

In the preceding 12 months, we may have collected or processed the following categories of Personal Information:

  • Identifiers — such as name, email address, device type, web browser, operating system or other similar identifiers;
  • Unique online identifiers — such as IP address, device IDs derived from device type, or other similar identifiers;
  • Certain commercial information — such as the Services, advertisement offerings or links to third party websites accessed, acquired or considered and related metrics;
  • Other electronic network activity information — such as browsing history, search history and information regarding interactions with our websites or our Services;
  • Location information – geo-location information about where you are accessing our Services (e.g., if you access our Services on your mobile or tablet device we may collect information about your device’s precise location to the extent feasible);
  • Online viewing activities and habits (e.g., videos viewed, pages viewed);
  • Consumer’s precise geolocation (where applicable);
  • Certain demographic data (e.g., gender, age, etc., where applicable); and

Business or commercial purposes for the collection and processing of Personal Information

We may have collected these categories of Personal Information for the following purposes (and including for any purposes otherwise described in this Privacy Policy):

  • Operate, manage, and maintain our businesses and infrastructure;
  • Provide, develop, improve, repair, and maintain our products and Services;
  • Performing services on behalf of our various businesses, such as user retention, providing content recommendations and/or processing information;
  • Fraud and crime prevention;
  • Debugging errors in systems;
  • Marketing and advertising;
  • Perform accounting, audit, and other internal functions, such as internal investigations;
  • Comply with law, legal process, and internal policies;
  • Internal research, analytics and development — e.g., user-preference analytics;
  • Developing, maintaining, provisioning or upgrading networks, products, services, or devices;
  • Payment processing and verification (where applicable); and
  • Customer support and inquiries.

We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about individuals.

Sources of Personal Information

We collect Personal Information:

  • Directly from you, including technical and usage information when you use our Services;
  • From linked sites, such as social media sites, and other third-party platforms;
  • From our various affiliated entities;
  • From our joint-ventures and promotional and strategic partners;
  • From information suppliers;
  • From distributors, service providers and other vendors; and
  • From marketing mailing lists

Such disclosure of Personal Information may be considered a “sale” or “sharing” of information under applicable state law. For example, under California law, a “sale” is the disclosure of Personal Information to a third party for monetary consideration or anything of value, and a “share” is the disclosure of Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

The categories of Personal Information that we disclose in this manner are as follows:

  • Identifiers — such as email address, device type, web browser, operating system or other similar identifiers;
  • Unique and online identifiers — such as IP address, device IDs derived from device type, or other similar identifiers;
  • Certain commercial information — such as Services accessed, acquired or considered;
  • Internet or other electronic network activity information — such as browsing history, search history and information regarding interactions with our websites or Services;
  • Location information – geo-location information about where you are accessing our Services (e.g., if you access our Services on your mobile or tablet device we may collect information about your device’s precise location to the extent feasible);
  • Online viewing activities and habits (e.g., videos viewed, pages viewed); and
  • Consumer’s precise geolocation (where applicable).

Some of our processing activities may constitute “targeted advertising” as that term is defined in applicable law.

Your U.S. state privacy rights

Depending on the state in which you reside, you may have certain privacy rights regarding your Personal Information, including (if applicable):

  • The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purposes for collecting, selling or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we collected about you;
  • The right to confirm whether or not we are processing your Personal Information;
  • 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 information to another controller without hindrance, where the processing is carried out by automated means;
  • The right to delete Personal Information that we collected from and/or about you, subject to certain exceptions;
  • The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions;
  • The right, if applicable, to opt out of (1) the sale or sharing of your Personal Information; (2) targeted advertising; and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • If we use or disclose sensitive Personal Information for purposes other than those allowed by applicable law, the right to limit our use or disclosure;
  • If we are required by applicable law to obtain your consent to process sensitive Personal Information, the right to withdraw your consent; and
  • The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

You can contact us with your request through one of the contact methods described under the section titled “Contact us“. We may ask you to provide information that will enable us to verify your identity in order to comply with your request to exercise your privacy rights. Consumers in some states may also authorize an agent to make requests on their behalf. In particular, when a California consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer to submit the request, or we may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request on their behalf. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request in accordance with the requirements of applicable law.

You may have the right to appeal our decisions made with respect to on your request. To appeal our decision on your request, you may contact us through one of the contact methods described under the section titled “Contact us“. Please enclose a copy of, or otherwise specifically reference, our decision on your request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

You may also request information about our practices related to the disclosure of your Personal Information by members of Upads Group to certain third parties for their direct marketing purposes. You may be able to opt out of our sharing of your Personal Information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. You can contact us with your request through one of the contact methods described under the section titled “Contact us“.

Your right to opt out of the sale or sharing of Personal Information

You may have the right to opt out of the sale of your Personal Information by contacting us through one of the contact methods described under the section titled “Contact us” or by clicking on the link “Do Not Sell or Share My Personal Information” at the bottom of the page.

However, please note that your use of our website may still be tracked by us and our vendors or partners to perform functions that are necessary for our businesses, such as hosting our website, ensuring there is no fraud (click-fraud, fraudulent or bot traffic), etc. These entities are contractually obligated to keep this information confidential, and will not use it for any purpose other than for the services they provide to our businesses.

Changes to this Privacy Policy

This Privacy Policy might be updated from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have any questions or concerns about our Privacy Policy or practices, please contact us at privacy@upads.com.

By using our website, you agree to the terms outlined in this Privacy Policy.