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PRIVACY POLICY

Effective October 2020

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About Artsai services

Adxcel Inc., DBA Artsai (collectively "Artsai" or "we" "us" "our") provides targeted advertising and marketing services for our customers - advertisers, advertising agencies and publishers.

Through our services, customers can create, manage and serve advertisements, as well as monitor the effectiveness of advertising campaigns.

To provide personalized advertising, our services may collect and use information about end users who are targeted with our ads. Our platform uses this information to help advertisers provide ads that are more relevant to you.

The following Privacy Policy describes:

To ensure online privacy, Artsai complies with the

Artsai is a member of the Network Advertising Initiative (NAI) and we adhere to the NAI Codes of Conduct. To learn more about the NAI and the Code of Conduct please visit: https://www.networkadvertising.org/code-enforcement/code

What Information We Collect

When we refer to the term "Information", we mean the data that is generated using our services, as well as the data that our customers receive from other sources and share with our services, as described below. For some of the data, Artsai acts as a data controller of personal information processed in order to serve personalized ads.

This Privacy Policy describes how information controlled by Artsai is used within our services; it does not apply to the use of information by our customers or other third parties outside of our services.

We may also receive information from third parties to enable targeted advertising on websites and mobile applications. We process such information in strict accordance with the permissions and restrictions imposed by the third party providing such data.

Personally Identifiable Information ("PII")

We do not collect or use any data that, by itself, directly identifies an individual, such as name, address, phone number, email address, government identifier, credit card information, bank account information and telephone or cell phone number.

Non-Personally Identifiable Information ("Non-PII")

Through our proprietary technology, we collect non-personally identifiable information about consumers who access advertising and other content through their systems, their publishers’ systems, and their advertisers’ systems. This includes, but is not limited to, IP addresses, browser type, web page views, application views, date, time and domains.

We collect the following categories of information for the purposes explained below:

How We Collect Information

Our services use cookies, tagging scripts and pixels to collect Information associated with a browser or mobile device.

Cookies are small text files stored in a web browser by a website or ad server. By saving information in a cookie, websites and servers can remember preferences or recognize web browsers from one visit to another or from one website to another.

Pixels and tagging scripts are elements allowing communication between a web browser and a server. Pixel is a small transparent image that is placed on a web page. A tagging script is a small piece of website code that is run by the web browser.

We may also receive Information from our partners via server-to-server connection, or via secure file transfer.

How We Use the Information We Collect

We use this information to serve ads to you that are more relevant to you and, in turn, improve performance of an Advertiser’s ad campaigns.

Specifically, we use this data for:

With Whom We Share Information

We may disclose information about you:

Our Use of Cookies

We use cookies in tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device.

Non-Cookie Technology for Tracking Outside European Territories

In respect of website visitors with IP addresses not from a European Territory, Artsai may use technologies other than cookie technology to recognize your computer, device or browser for the purposes of interest-based advertising, analyzing engagement with ads or content, measuring the effectiveness of a particular ad campaign or marketing effort, to monitor against fraud or misuse of our Services, or in other ways described in this Privacy Policy in How We Use the Data We Collect. This use of non-cookie technology may be used in addition to cookies, or separately, to collect and record data about your web browsing activities on browsers, search engines or other platforms that may not utilize Artsai technology. You may opt-out of tracking via non-cookie technologies by employing the respective opt-out techniques described in Your Choices and Opting-Out of Targeted Ads.

Data Retention

International Data Transfers

Information may be transferred to and processed in countries outside of the European Union. These countries may have data protection laws that are different from the laws of your country and, in some cases, may not be as protective.

Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Policy and take steps, where necessary, to ensure that international transfers comply with applicable laws.

Legal Basis for Processing

If you interact with our services from the European Economic Area, Switzerland and United Kingdom (even if it leaves the European Economic Area ), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally process personal information from you only where we have your consent to do so (including as a processor for a third party data controller that has obtained your consent), where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to process your request to exercise your rights regarding your personal data or that of another person who shares your device).

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you wish to learn more about specific legal ground(s) we rely on to process your information for any particular purpose (including any legitimate interests we have to process information), then please contact us using the details provided below under "Contact Us".

Information Relating to Children

Our products and services are not designed or intended for children (as defined in applicable data protection laws). We do not knowingly collect personal information from children on the websites we operate or through our services. Please advise us if you are aware of our having received personal information from a child, in which case we will take appropriate steps to delete it. For these purposes, "children" and "child" refer to ages defined by applicable law in the countries where we provide our services.

Data Security and Protection

We apply technical, administrative and organizational security measures to protect the personal data we collect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.

Linking to Other Sites

Ads served by Artsai usually link to other websites, which may have privacy assurance practices that differ from ours. Artsai does not control and cannot be held responsible for the content of these websites and data collection on these web sites by any third party. To make sure your privacy is protected, please consult the respective privacy policy of the web site you are visiting.

Your Data Protection Rights

You have the following data protection rights:

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Your Choices and Opting-Out of Targeted Ads

We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads (sometimes called "interest-based ads") you receive and how we use your data.

Opting-out of this type of advertising through the below methods will not prevent you from seeing ads, but those ads will likely be less relevant because they will not be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.

These settings must be performed on each device (including each internet browser on each device) for which you want to opt-out. For more information on our data collection and processing policies and practices, please review this entire Privacy Policy. Since privacy controls change and are updated from time to time, Artsai may modify the following options and information at any time.

Privacy Notice And Disclosures For California Residents

This section applies solely to the personal data of users who reside in the State of California ("consumers" or "you") and supplements the information contained in Artsai’ Privacy Policy. We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices: The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 6-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Contact Us

Artsai has appointed a Data Protection Officer. If you have any questions or believe your personal information has been used in a way that is not consistent with this policy or applicable legislation, or you have any other data protection related issues or queries, please contact our Data Protection Officer by e-mail sent to dpo@artsai.com.

Written inquiries may be addressed to:

Data Protection Officer
Artsai
600 California St,
San Francisco, CA 94108, USA

More Information

To learn more about data collection, online behavioral advertisements, web analytics, cookies or other aspects from the perspective of Internet security and privacy, please visit these public sites: www.youronlinechoices.com and www.iabeurope.eu.

Artsai complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, and Switzerland transferred to the United States pursuant to Privacy Shield. Artsai has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Artsai is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to dpo@artsai.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to dpo@artsai.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Artsai’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Artsai remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Artsai proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Artsai commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Artsai by email at dpo@artsai.com

Artsai has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Updates

We may update this policy from time to time. We will post a prominent notice on our website notifying users when it is updated. We ensure that privacy practices described in this privacy policy are up to date and reflect current ad-serving and data collection mechanisms employed by Artsai.

This Privacy Policy will always include information on the effective date of the most recent version.