Adextrem’s Privacy Policy
Effective Date: October 11, 2018
This privacy policy is subject to change. If we make any material or substantive changes in the way that we use any form of data collected, we will post a clear notice of those changes on our Site and within this privacy policy.
Contact Information
For questions or concerns relating to privacy, please send us an email at 
. Alternatively, you may contact us at:
Data Protection Officer
Prime Services 2021 SL
Torre NN, 4th Floor
C/ Tarragona, 157
08014 Barcelona
Adextrem Media Inc (“Adextrem”), through the Adextrem Program, provides advertisers and publishers (“Business Partners”) access to a set of technologies and processes designed to display advertisements to consumers viewing a publisher’s website(s) (the “Ad Rewards Ads”).
This privacy policy describes Adextrem’s privacy practices as they pertain to (i) visitors to our website located at www.adextrem.com (our “Site”), and (ii) our targeted advertising technology service (“Technology”). If you have any questions about this Privacy Policy, please feel free to contact us at .
We are committed to safeguarding the privacy of our service users. This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
Information Collected via the Site
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent or our legitimate interests, namely monitoring and improving our website and service.
We may process your account data ("account data"). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business.
We may process your information included in your personal profile on our website ("profile data"). The profile data may include but not limited to your name, address, telephone number, email address, gender, date of birth, and interests and hobbies. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business.
We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may be processed for the purposes of operating our Site, providing our services, ensuring the security of our Site and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website, services and business. We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business.
We may process information contained in any enquiry you submit to us regarding our website or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include, your name, your contact details, and information contained in communications between us. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent or our legitimate interests, namely the proper management of our customer relationships.
We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our Site ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and Adextrem and our legitimate interests, namely the proper administration of our website and business.
We may process information that you provide to us for the purpose of subscribing to our email notifications ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
SHARING YOUR PERSONAL INFORMATION
Financial transactions relating to our website and services are handled by our payment services providers, TransferWise (privacy policy can be found here: https://transferwise.com/terms-and-conditions), Paxum (privacy policy can be found here: https://www.paxum.com/us/legal/privacy-policy/) and Paypal (privacy policy can be found here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
We have offices in the United Arab Emirates. The European Commission has made an "adequacy decision" with respect to the data protection laws. Transfers to United Arab Emirates will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
The hosting facilities for our website are situated in Germany. The European Commission has made an "adequacy decision" with respect to the data protection laws. Transfers to Germany will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Cookies and Web Beacons
Adextrem uses cookies and web beacons in connection with our Technology. as those cookies are not strictly necessary for the provision of our Site and services, we will ask you to consent to our use of cookies when you first visit our website.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies help Adextrem better understand the effectiveness of an Adextrem Ad (for example, by tracking the way in which you may respond to, select and interact with an Ad Rewards Ad or any content provided therein, or the location and context in which you view an Ad Rewards Ad). Adextrem’s cookies also help control the number of times you view an Ad Rewards Ad. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the websites you visit.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
a. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
b. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
c. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
d. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
e. https://support.apple.com/kb/PH21411 (Safari); and
f. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge);
If you do not accept cookies, however, you may not be able to enjoy the full functionality of many of the websites you visit. As an alternative to deletion/disabling of cookies, you can also choose to opt out of cookie-based data collection please email us at “”. If you block cookies, you may not be able to use all the features on our Site.
Third Party Websites
Ad Rewards Ads may contain links to other websites, including those of our Business Partners. Such websites may use cookies and/or other data collection tools. Adextrem is not responsible for the privacy practices, policies or the content of such websites. Adextrem encourages everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. Adextrem has no control over the use of any information by third party websites, and you should exercise caution when deciding to disclose any sets of data as defined herein.
While ADX contractually requires that our Business Partners adhere to applicable laws, Adextrem does not have access to, or control of, the cookies and/or other data collection tools that may be placed on any advertisement by a third-party. This Privacy Policy does not cover the use of cookies and/or other data collection tools by any third party.
Relating to Children
Our products and services are designed for those 18 years of age and older. We do not knowingly collect PII from anyone under the age of 18. If we are made aware that we have received PII from someone under 18, we will use reasonable efforts to remove that information from our records.
Info Storage / Security / Integrity
We retain the Non-PII collected via our Technology for up to 180 days in order to ensure that our Technology is functioning properly. After 180 days, we render this information anonymous and store it for up to five years.
Information Security
The security of your information is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to the use of encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
If you have any questions about our security practices, please send an email to us at .
Data Integrity
Adextrem processes information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
USER RIGHTS
Adextrem recognizes the following rights with respect to the use of its Site and Technology:
a. the right to access;
b. the right to rectification;
c. the right to erasure;
d. the right to restrict processing;
e. the right to object to processing;
f. the right to data portability;
g. the right to complain to a supervisory authority; and
h. the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
To the extent that the legal basis for our processing of your personal data is:
a. consent; or
b. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us at the address or email address provided herein.
Enforcement, Questions and Complaints
Adextrem uses myriad processes to ensure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.