Fields marked with (*) are mandatory.
(**) The owner informed that the above consent may be revoked at any time by sending specific e-mails to the following address: info@adhubmedia.com or through the the opt-out present in each newsletter. This revocation does not affect the lawfulness of the treatment on the seriously previously lent, but protected to stay updated on the AdHub Media world.
1.1 Cookies: Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. On each subsequent visit, the browser sends the cookies back to the originating website. Cookies may be stored only for the duration of a specific website session (i.e., session cookies) or for a longer period, independent of the session (i.e., persistent cookies).
1.2 Personal Data: any information relating to an identified or identifiable natural person, directly or indirectly, by reference to a name, identification number, location data, online identifier, or elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
1.3 Service Agreement: the agreement signed by AdHub Media with Registered Users for the provision of the Service.
1.4 Privacy Notice: this document, comprising the privacy notice on the processing of Personal Data and the cookie notice.
1.5 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.6 Service: service for optimizing advertising campaign spaces on websites made available by Registered Users.
1.7 Additional Services: option to submit spontaneous job applications to work with AdHub Media and to request contact information from AdHub Media by filling out the form available on the Website.
1.8 Website: this website.
1.9 Processing: any operation or set of operations performed on Personal Data, such as, by way of example, collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, restriction, erasure, or destruction.
1.10 Users: users of the Website, including Registered Users.
1.11 Registered Users: users registered on the Website who have a personal account to access the services offered by AdHub Media under the Service Agreement.
The Data Controller referred to in this Privacy Notice is AdHub Media S.r.l. (“AdHub Media”), with registered office at Via Paolo da Cannobio, 9, 20122 Milan, VAT number IT13542920965. Any request from Users/Registered Users regarding the Processing of their Personal Data by AdHub Media (including the exercise of the rights referred to in point 8 below) must be addressed to AdHub Media by mail at the registered office or by email at the following address info@adhubmedia.com.
AdHub Media collects and uses Users’/Registered Users’ Personal Data for the following purposes:
a) Allow browsing on the Website, primarily through the use of Cookies.
➢ The collection of Personal Data for the purpose referred to in letter a) is governed by the Cookie Notice, available at the following link https://www.adhubplatform.com/informativa-cookie/, which AdHub Media recommends reading.
b) Provide Additional Services to Users.
➢ The collection of Personal Data for the purpose referred to in letter b) is necessary for the User to access the Additional Services, and any refusal prevents the User from using the Additional Services. This Processing is based on the User’s free, specific, informed, and unambiguous consent, expressed through a statement or positive action (e.g., flag) on the Website. Withdrawal of consent may be exercised at any time by following the instructions in point 7 letter a) of this Privacy Notice.
c) Allow Registered Users to access their personal accounts to use the Service.
➢ The collection of Personal Data for the purpose referred to in letter c) is necessary for Registered Users to use the Service, in accordance with the terms and conditions of the Service Agreement, and any refusal prevents Registered Users from using the Service. This Processing is based on the execution of the Service Agreement.
d) Perform statistical analyses on Website usage to improve the Website. Where possible, AdHub Media uses anonymized Personal Data (Personal Data that does not identify or make Users identifiable) for this purpose.
➢ The Processing referred to in letter d) is based on the legitimate interest of AdHub Media, consisting of the benefit the Company may derive from providing a Website that facilitates navigation and improves the User experience, which AdHub Media considers to prevail over the Users’ right to privacy. Objection to this Processing (where it does not involve anonymized data) may be exercised at any time by following the instructions in point 7 letter g) of this Privacy Notice.
AdHub Media collects Personal Data through the following methods:
a) Personal Data collected automatically by the Website: this includes Personal Data collected automatically by the Website through, but not limited to, Cookies (for further information, AdHub Media recommends reading the Cookie Notice provided below);
b) Personal Data entered into the Website by Users: this includes Personal Data provided by Users to access Additional Services, for example, through the contact form available at the link: https://www.adhubplatform.com/contatti/.
c) Personal Data explicitly communicated to AdHub Media by Users through offline methods: this includes Personal Data directly communicated to AdHub Media employees and collaborators by Users through methods other than the Website.
Personal Data is processed by AdHub Media and/or by third parties, selected for reliability and competence, to whom it may be communicated where necessary or appropriate, provided that such parties are within the European Union. In particular, AdHub Media informs Users that Personal Data may be processed by, and/or communicated to:
a) employees and/or collaborators of AdHub Media;
b) third-party service providers necessary to ensure the functioning of the Website (e.g., hosting service providers, IT technicians);
c) third parties providing Website navigation data analysis services;
d) third parties contractually linked to AdHub Media, necessary for the provision of the services under the Service Agreement (e.g., AdHub Media's regional partners).
Personal Data is retained by AdHub Media for the period strictly necessary to achieve the purposes for which it was collected, as indicated in point 3 above. In particular, unless the right to withdraw consent under point 8 letter a) or the right to object under point 8 letter g) is exercised, AdHub Media retains Personal Data for the following periods:
a) Cookies: for the purpose referred to in point 3 letter a), please refer to the Cookie Notice;
b) Personal Data collected from the "contact" form: for the purpose referred to in point 3 letter b), for a period of 3 months from receipt of the contact request, to verify whether the User requires further assistance on the same topic. As an exception to this period, if a complaint or grievance is submitted through the "contact" form, the User's Personal Data will be retained for the period referred to in letter d) below;
c) Personal Data for managing Registered Users' accounts: for the purpose referred to in point 3 letter c), for the duration of the Service Agreement;
d) in any case, AdHub Media is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to the information necessary to comply with legal obligations and to allow AdHub Media to establish, exercise, or defend a legal claim.
Upon expiry of these periods, AdHub Media will automatically delete the collected Personal Data or irreversibly anonymize it.
Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Privacy Notice, each User/Registered User has the right to:
a) with reference to the Processing referred to in point 3 letter b), withdraw consent at any time without affecting the lawfulness of Processing, by sending an email to AdHub Media or exercising the opt-out in AdHub Media's commercial communications (cf. Art. 7 of the Regulation);
b) request access to their Personal Data and information about the related Processing, as well as a copy in electronic format, unless the User/Registered User specifically requests otherwise (cf. Art. 15 of the Regulation);
c) request rectification and/or completion of their Personal Data without undue delay (cf. Art. 16 of the Regulation);
d) for specific reasons (e.g., unlawful Processing, withdrawal of consent, absence of the purpose for Processing), request erasure of their Personal Data without undue delay (cf. Art. 17 of the Regulation);
e) in specific cases (e.g., inaccuracy of Personal Data, unlawfulness of Processing, exercise of a legal claim), request restriction of Processing (Art. 18 of the Regulation);
f) receive their Personal Data in a structured, commonly used, and machine-readable format and, consequently, exercise the right to data portability and transmit such data to another controller (Art. 19 of the Regulation);
g) with reference to the Processing referred to in point 3 letter d), object at any time to the Processing of their Personal Data by sending an email to AdHub Media (cf. Art. 21 of the Regulation);
h) be informed by AdHub Media without undue delay of any breaches or unauthorized access by third parties to its systems containing Personal Data (so-called data breach - Art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country where they reside, work, or where they believe their rights have been violated (cf. Art. 77 of the Regulation);
For further information on the terms and conditions for exercising the rights granted to Users/Registered Users, the latter may consult the text of the EU Regulation published at the following link http://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX:32016R0679&from=IT, or contact AdHub Media as provided in point 2 of this Privacy Notice.
1.1 General Terms: general terms and conditions governing the provision of the Service.
1.2 Cookies: Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. On each subsequent visit, the browser sends the Cookies back to the originating website or to another website. Cookies may be stored only for the duration of a specific website session (i.e., session Cookies) or for a longer period, independent of the session (i.e., persistent Cookies).
1.3 Advertising Campaigns: advertising campaigns sold by AdHub Media on Publisher websites.
1.4 Personal Data: any information relating to an identified or identifiable natural person, directly or indirectly, by reference to a name, identification number, location data, online identifier, or elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
1.5 Privacy Notice: this document, comprising the privacy notice on the processing of Personal Data related to the Service.
1.6 Profiling: a form of Personal Data Processing, through automated—in whole or in part—procedures aimed at evaluating or predicting the Publisher’s preferences and interests.
1.7 Publisher: an adult natural person or legal entity, represented by its legal representative, who uses the Service offered by AdHub Media to publish advertisements sold by AdHub Media on their own website.
1.8 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.9 Service: organization and management of Advertising Campaigns on Publisher Website spaces through native, video, and display ads.
1.10 Website: this website.
1.11 Publisher Website: website owned and/or managed by the Publisher where the Service is provided.
1.12 Data Controller: AdHub Media S.r.l.
1.13 Processing: any operation or set of operations performed on Personal Data, such as, by way of example, collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, restriction, erasure, or destruction.
1.14 Users: users of Publisher Websites.
The Data Controller referred to in this Privacy Notice is:
a) AdHub Media S.r.l., with registered office at Via Paolo da Cannobio, 9 - 20122 Milan, VAT number IT13542920965 (“AdHub Media”). Any request from the Publisher regarding the Processing of their Personal Data by the Data Controller (including the exercise of the rights referred to in point 8 below) must be addressed to AdHub Media by mail at the registered office or by email at the following address info@adhubmedia.com.
The Data Controller collects and uses the Personal Data of Publishers and Users for the following purposes:
a) allow browsing on the Website, primarily through the use of Cookies.
b) allow Publishers to register on the Website and create a personal account for monitoring the Service;
c) provide the Service to Publishers, including the management of administrative and accounting relationships resulting from the acceptance of the General Terms and the sending of communications strictly related to the provision of the Service, of a technical (e.g., notification of Advertising Campaign performance) and/or administrative nature (e.g., updates to this Privacy Notice).
➢ The collection of Personal Data for the purposes referred to in letters b) and c) is necessary for the Publisher to use the Service. Any refusal prevents the Publisher from using the Service as provided in the General Terms. These Processing activities are based on the Publisher’s acceptance of the General Terms and the related pre-contractual measures proposed by AdHub Media.
d) subject to optional consent, perform statistical analyses and market research, send informational and promotional materials, notify and invite to promotional initiatives by AdHub Media;
➢ The purpose referred to in letter e) is optional, and any refusal by the Publisher prevents them from benefiting from marketing activities (including direct and personalized marketing) by AdHub Media. These Processing activities are based on the Publisher’s free, specific, informed, and unambiguous consent, expressed through a statement or positive action (e.g., flag) on the Website. Consent may be withdrawn at any time by following the instructions in point 7 letter a) of this Privacy Notice.
e) Perform statistical analyses, market research, improve the presentation of the Service and the use of the Website by Publishers. Where possible, for this purpose, the Data Controller uses anonymized Personal Data.
➢ The Processing referred to in letter f) is based on the Data Controller’s legitimate interest, consisting of the benefit derived from offering Publishers services more aligned with their preferences during Website browsing, considering that it is also in the Publishers’ interest to use personalized services. For this reason, the Data Controller believes that the legitimate interest in developing and improving the Website and Service prevails over the Publishers’ right to privacy. Objection to this Processing (where it involves Personal Data and not anonymized data) may be exercised at any time by following the instructions in point 7 letter f) of this Privacy Notice.
The Data Controller collects Personal Data through the following methods:
a) Personal Data entered into the Website by Publishers: this includes Personal Data provided, by way of example but not limited to, for browsing, registering, and accessing the Service offered on the Website;
b) Personal Data explicitly communicated by Publishers through offline methods: this includes Personal Data provided, for example, to AdHub Media's customer service (in case of contact requests) or collected during events and/or initiatives organized by the Data Controller or communicated when accepting the General Terms;
c) Personal Data collected automatically by the Website: this includes Personal Data collected automatically by the Website through, but not limited to, Cookies.
Personal Data is processed by the Data Controller and/or by third parties, selected for reliability and competence, to whom it may be communicated where necessary or appropriate, provided that such parties are within the European Union. In particular, the Data Controller informs Publishers that Personal Data may be processed by, and/or communicated to:
a) employees and/or collaborators of the Data Controller;
b) third-party service providers necessary to ensure the functioning of the Website (e.g., hosting service providers);
c) third-party service providers necessary for the use of the Service (e.g., payment processors);
d) third-party IT and Website maintenance service providers;
e) third-party technicians providing Website navigation data analysis services;
f) subject to the Publisher's optional consent, third parties providing automated newsletter and/or any other type of commercial communication services, marketing, promotion, and analysis of consumption habits and choices.
Personal Data is retained by AdHub Media for the period strictly necessary to achieve the purposes for which it was collected, as indicated in point 3 above. In particular, unless the right to withdraw consent under point 7 letter a) and/or the right to object under point 7 letter f) is exercised:
a) for the use of the Service, the Data Controller retains Personal Data for the duration of the General Terms and for an additional 10 (ten) years from the termination of the Service;
b) for commercial purposes, the Data Controller retains Personal Data for a maximum period of 2 (two) years from the Publisher's consent.
In any case, the Data Controller is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to the information necessary to comply with legal obligations and to allow the Data Controller to establish, exercise, or defend a legal claim and/or in tax audits.
Upon expiry of these periods, the Data Controller will automatically delete the collected Personal Data or irreversibly anonymize it.
Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Privacy Notice, each Publisher has the right to:
a) with reference to the Processing referred to in point 3 letters d) and e), withdraw consent at any time without affecting the lawfulness of Processing, by sending an email to AdHub Media, exercising the opt-out in commercial communications, or by deleting the account directly on the Website (cf. Art. 7 of the Regulation);
b) request access to their Personal Data and information about the related Processing, as well as a copy in electronic format, unless the User and/or Publisher specifically requests otherwise (cf. Art. 15 of the Regulation);
c) request rectification and/or completion of their Personal Data without undue delay (cf. Art. 16 of the Regulation);
d) for specific reasons (e.g., unlawful Processing, withdrawal of consent, absence of the purpose for Processing), request erasure of their Personal Data without undue delay (cf. Art. 17 of the Regulation);
e) in specific cases (e.g., inaccuracy of Personal Data, unlawfulness of Processing, exercise of a legal claim), request restriction of Processing (Art. 18 of the Regulation);
f) with reference to the Processing referred to in point 3 letters d) and e), object at any time to the Processing of their Personal Data by sending an email to AdHub Media (cf. Art. 21 of the Regulation);
g) receive their Personal Data in a structured, commonly used, and machine-readable format, with the right to portability to another controller without hindrance (Art. 20 of the Regulation);
h) be informed by AdHub Media without undue delay of any breaches or unauthorized access by third parties to its systems containing Personal Data (so-called data breach - cf. Art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country where they reside, work, or where they believe their rights have been violated (cf. Art. 77 of the Regulation);
For further information on the terms and conditions for exercising the rights granted to the User, the latter may consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX:32016R0679, or contact AdHub Media as provided in point 2 of this Privacy Notice.
1. Third-party analytical Cookies
Google Analytics Cookies
a) Purpose:
these are Cookies provided by Google Inc. to monitor, in an anonymous and aggregated form, the statistical analysis of User traffic on the Publisher Website to adapt the Publisher Website to the results of such analysis, in line with the interests shown by the Users.
b) Data collected:
data related to the computer and the User's visit to the Publisher Website, which in no case allows AdHub Media to independently trace the User's Personal Data: (i) the domain from which the User accesses the Internet; (ii) the web address from which the User connected to the Website, if available; (iii) the date and time of connection to the Publisher Website, how long it lasted, and which pages were visited; (iv) the computer's operating system and the browser used by the User; (v) aggregated demographic details of Users accessing the Publisher Website.
c) Duration: session Cookies.
For further information on Google Analytics Cookies, the User may consult the following webpage: https://tools.google.com/dlpage/gaoptout.
2. AdHub Media profiling Cookies and third-party advertising Cookies
AdHub Media profiling Cookies:
a) Name: 4wnet.data.cookie.
b) Purpose: AdHub Media uses profiling Cookies to improve the commercial experience of Users by offering content tailored to their tastes and personal habits, as well as sending advertising communications related only to products that are most relevant to the User's interests.
c) Data collected: data related to the computer and the User's visit to the Publisher Website, to create a "navigation profile" of the User based on their searches and the most frequently visited sections of the Publisher Website.
d) Duration: 30 days.
e) Place of Processing: Italy.
Third-party advertising Cookies:
a) Purpose:
third-party advertising Cookies are provided by AdHub Media's partners, through links within the Advertising Campaign, to send information and commercial offers based on interests associated with the User's online activity. These Cookies do not personally identify Users.
b) Data collected:
data and information on the User's online preferences and/or habits, such as searches performed, page load frequency, or activity on other third-party websites.
c) Duration:
session and persistent Cookies.
For further information on third-party advertising Cookies, the User may consult the following webpages:
i) SSP (Sell Side Platform): Platforms used by AdHub Media to monetize advertising spaces aggregated on Publisher Websites
1. Freewheel: http://freewheel.tv/privacy-policy/
2. Improve: https://www.improvedigital.com/platform-privacy-policy/
3. Rubicon: https://rubiconproject.com/privacy-policy/?lang=it
4. Adform. https://site.adform.com/privacy-policy-opt-out/
5. OZ Digital: https://www.ozdigital.com/en/privacy-policy/
6. AOL: https://policies.oath.com/in/en/oath/privacy/index.html
7. Spotx: https://www.spotx.tv/privacy-policy/
8. Google: https://policies.google.com/privacy?hl=it&gl=it
9. Sublime: http://sublimeskinz.com/privacy-en
10. Criteo: https://www.criteo.com/privacy/
11. Onetag: https://onetag.net/privacy/
ii) DMP (Data Management Platform): platforms used by AdHub Media to create/manage Advertising Campaigns with audience-based targeting
1. Nugg.ad: https://nugg.ad/en/privacy/general-information.html
2. Nielsen VisualDNA: https://www.visualdna.com/privacy-policy/
3. Nielsen Exelate: http://www.exelate.com/privacy/services-privacy-policy/
4. Neustar: https://www.neustar.biz/privacy/opt-out
5. Navegg: https://www.navegg.com/en/privacy-policy/
6. Audience Rate: http://www.audiencerate.co.uk/privacy.html
7. Omnicom Media Group: http://www.omgitaly.it/pdf/Cookies_Policy_OMG.pdf
The Publisher must inform the User of the following.
The User may give their consent to the use of the Cookies described in the previous section 8 through the methods indicated on the Publisher Website (via an immediate pop-up information banner).
Consent may be modified at any time.
That said, with reference to all Cookies in the Service, the User may modify the related settings according to the methods provided in the control panels of the browser used, such as, by way of example:Furthermore, with specific reference to profiling and advertising Cookies (see point 8.2 of this Privacy Notice), in addition to using the tools provided by the browser to enable or disable individual Cookies, the Data Controller informs that if the User does not wish to receive targeted advertisements (i.e., based on their online behavior) displayed by the Data Controller or the third parties mentioned above or unknown to the Data Controller, they may disable the display of such targeted advertisements by clicking here www.youronlinechoices.com/it/le-tue-scelte and configuring the setting for AdHub Media with the appropriate ON/OFF button. The above procedure refers to the specific browser the User is using to access the Publisher Website at a given time. If the User uses multiple browsers to navigate the Internet and does not wish to see targeted advertisements delivered by AdHub Media under any circumstances, they must repeat the above operation for each browser.
- Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en
- Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
- Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
- Safari: https://support.apple.com/kb/PH19255?locale=it_IT
When the User disables the Data Controller's services, the latter places a technical Cookie in the User's browser to store their choice and respect it during subsequent online navigation. If this technical Cookie is deleted from the browser, the User must repeat the disabling procedure.
The above procedure will block only targeted advertisements delivered by the Data Controller and not those from any other third parties.
1.1 Cookies: Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. On each subsequent visit, the browser sends the cookies back to the originating website. Cookies may be stored only for the duration of a specific website session (i.e., session cookies) or for a longer period, independent of the session (i.e., persistent cookies).
1.2 Personal Data: any information relating to an identified or identifiable natural person, directly or indirectly, by reference to a name, identification number, location data, online identifier, or elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
1.3 Service Agreement: the agreement signed by AdHub Media with Registered Users for the provision of the Service.
1.4 Privacy Notice: this document, comprising the privacy notice on the processing of Personal Data and the cookie notice.
1.5 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.6 Service: service for optimizing advertising campaign spaces on websites made available by Registered Users.
1.7 Additional Services: option to submit spontaneous job applications to work with AdHub Media and to request contact information from AdHub Media by filling out the form available on the Website.
1.8 Website: this website.
1.9 Processing: any operation or set of operations performed on Personal Data, such as, by way of example, collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, restriction, erasure, or destruction.
1.10 Users: users of the Website, including Registered Users.
1.11 Registered Users: users registered on the Website who have a personal account to access the services offered by AdHub Media under the Service Agreement.
The Data Controller referred to in this Privacy Notice is AdHub Media S.r.l. (“AdHub Media”), with registered office at Via Paolo da Cannobio, 9, 20122 Milan, VAT number IT13542920965. Any request from Users/Registered Users regarding the Processing of their Personal Data by AdHub Media (including the exercise of the rights referred to in point 8 below) must be addressed to AdHub Media by mail at the registered office or by email at the following address info@adhubmedia.com.
AdHub Media collects and uses Users’/Registered Users’ Personal Data for the following purposes:
a) Allow browsing on the Website, primarily through the use of Cookies.
➢ The collection of Personal Data for the purpose referred to in letter a) is governed by the Cookie Notice, available at the following link https://www.adhubplatform.com/informativa-cookie/, which AdHub Media recommends reading.
b) Provide Additional Services to Users.
➢ The collection of Personal Data for the purpose referred to in letter b) is necessary for the User to access the Additional Services, and any refusal prevents the User from using the Additional Services. This Processing is based on the User’s free, specific, informed, and unambiguous consent, expressed through a statement or positive action (e.g., flag) on the Website. Withdrawal of consent may be exercised at any time by following the instructions in point 7 letter a) of this Privacy Notice.
c) Allow Registered Users to access their personal accounts to use the Service.
➢ The collection of Personal Data for the purpose referred to in letter c) is necessary for Registered Users to use the Service, in accordance with the terms and conditions of the Service Agreement, and any refusal prevents Registered Users from using the Service. This Processing is based on the execution of the Service Agreement.
d) Perform statistical analyses on Website usage to improve the Website. Where possible, AdHub Media uses anonymized Personal Data (Personal Data that does not identify or make Users identifiable) for this purpose.
➢ The Processing referred to in letter d) is based on the legitimate interest of AdHub Media, consisting of the benefit the Company may derive from providing a Website that facilitates navigation and improves the User experience, which AdHub Media considers to prevail over the Users’ right to privacy. Objection to this Processing (where it does not involve anonymized data) may be exercised at any time by following the instructions in point 7 letter g) of this Privacy Notice.
AdHub Media collects Personal Data through the following methods:
a) Personal Data collected automatically by the Website: this includes Personal Data collected automatically by the Website through, but not limited to, Cookies (for further information, AdHub Media recommends reading the Cookie Notice provided below);
b) Personal Data entered into the Website by Users: this includes Personal Data provided by Users to access Additional Services, for example, through the contact form available at the link: https://www.adhubplatform.com/contatti/.
c) Personal Data explicitly communicated to AdHub Media by Users through offline methods: this includes Personal Data directly communicated to AdHub Media employees and collaborators by Users through methods other than the Website.
Personal Data is processed by AdHub Media and/or by third parties, selected for reliability and competence, to whom it may be communicated where necessary or appropriate, provided that such parties are within the European Union. In particular, AdHub Media informs Users that Personal Data may be processed by, and/or communicated to:
a) employees and/or collaborators of AdHub Media;
b) third-party service providers necessary to ensure the functioning of the Website (e.g., hosting service providers, IT technicians);
c) third parties providing Website navigation data analysis services;
d) third parties contractually linked to AdHub Media, necessary for the provision of the services under the Service Agreement (e.g., AdHub Media's regional partners).
Personal Data is retained by AdHub Media for the period strictly necessary to achieve the purposes for which it was collected, as indicated in point 3 above. In particular, unless the right to withdraw consent under point 8 letter a) or the right to object under point 8 letter g) is exercised, AdHub Media retains Personal Data for the following periods:
a) Cookies: for the purpose referred to in point 3 letter a), please refer to the Cookie Notice;
b) Personal Data collected from the "contact" form: for the purpose referred to in point 3 letter b), for a period of 3 months from receipt of the contact request, to verify whether the User requires further assistance on the same topic. As an exception to this period, if a complaint or grievance is submitted through the "contact" form, the User's Personal Data will be retained for the period referred to in letter d) below;
c) Personal Data for managing Registered Users' accounts: for the purpose referred to in point 3 letter c), for the duration of the Service Agreement;
d) in any case, AdHub Media is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to the information necessary to comply with legal obligations and to allow AdHub Media to establish, exercise, or defend a legal claim.
Upon expiry of these periods, AdHub Media will automatically delete the collected Personal Data or irreversibly anonymize it.
Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Privacy Notice, each User/Registered User has the right to:
a) with reference to the Processing referred to in point 3 letter b), withdraw consent at any time without affecting the lawfulness of Processing, by sending an email to AdHub Media or exercising the opt-out in AdHub Media's commercial communications (cf. Art. 7 of the Regulation);
b) request access to their Personal Data and information about the related Processing, as well as a copy in electronic format, unless the User/Registered User specifically requests otherwise (cf. Art. 15 of the Regulation);
c) request rectification and/or completion of their Personal Data without undue delay (cf. Art. 16 of the Regulation);
d) for specific reasons (e.g., unlawful Processing, withdrawal of consent, absence of the purpose for Processing), request erasure of their Personal Data without undue delay (cf. Art. 17 of the Regulation);
e) in specific cases (e.g., inaccuracy of Personal Data, unlawfulness of Processing, exercise of a legal claim), request restriction of Processing (Art. 18 of the Regulation);
f) receive their Personal Data in a structured, commonly used, and machine-readable format and, consequently, exercise the right to data portability and transmit such data to another controller (Art. 19 of the Regulation);
g) with reference to the Processing referred to in point 3 letter d), object at any time to the Processing of their Personal Data by sending an email to AdHub Media (cf. Art. 21 of the Regulation);
h) be informed by AdHub Media without undue delay of any breaches or unauthorized access by third parties to its systems containing Personal Data (so-called data breach - Art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country where they reside, work, or where they believe their rights have been violated (cf. Art. 77 of the Regulation);
For further information on the terms and conditions for exercising the rights granted to Users/Registered Users, the latter may consult the text of the EU Regulation published at the following link http://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX:32016R0679&from=IT, or contact AdHub Media as provided in point 2 of this Privacy Notice.
1.1 General Terms: general terms and conditions governing the provision of the Service.
1.2 Cookies: Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. On each subsequent visit, the browser sends the Cookies back to the originating website or to another website. Cookies may be stored only for the duration of a specific website session (i.e., session Cookies) or for a longer period, independent of the session (i.e., persistent Cookies).
1.3 Advertising Campaigns: advertising campaigns sold by AdHub Media on Publisher websites.
1.4 Personal Data: any information relating to an identified or identifiable natural person, directly or indirectly, by reference to a name, identification number, location data, online identifier, or elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
1.5 Privacy Notice: this document, comprising the privacy notice on the processing of Personal Data related to the Service.
1.6 Profiling: a form of Personal Data Processing, through automated—in whole or in part—procedures aimed at evaluating or predicting the Publisher’s preferences and interests.
1.7 Publisher: an adult natural person or legal entity, represented by its legal representative, who uses the Service offered by AdHub Media to publish advertisements sold by AdHub Media on their own website.
1.8 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.9 Service: organization and management of Advertising Campaigns on Publisher Website spaces through native, video, and display ads.
1.10 Website: this website.
1.11 Publisher Website: website owned and/or managed by the Publisher where the Service is provided.
1.12 Data Controller: AdHub Media S.r.l.
1.13 Processing: any operation or set of operations performed on Personal Data, such as, by way of example, collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, restriction, erasure, or destruction.
1.14 Users: users of Publisher Websites.
The Data Controller referred to in this Privacy Notice is:
a) AdHub Media S.r.l., with registered office at Via Paolo da Cannobio, 9 - 20122 Milan, VAT number IT13542920965 (“AdHub Media”). Any request from the Publisher regarding the Processing of their Personal Data by the Data Controller (including the exercise of the rights referred to in point 8 below) must be addressed to AdHub Media by mail at the registered office or by email at the following address info@adhubmedia.com.
The Data Controller collects and uses the Personal Data of Publishers and Users for the following purposes:
a) allow browsing on the Website, primarily through the use of Cookies.
b) allow Publishers to register on the Website and create a personal account for monitoring the Service;
c) provide the Service to Publishers, including the management of administrative and accounting relationships resulting from the acceptance of the General Terms and the sending of communications strictly related to the provision of the Service, of a technical (e.g., notification of Advertising Campaign performance) and/or administrative nature (e.g., updates to this Privacy Notice).
➢ The collection of Personal Data for the purposes referred to in letters b) and c) is necessary for the Publisher to use the Service. Any refusal prevents the Publisher from using the Service as provided in the General Terms. These Processing activities are based on the Publisher’s acceptance of the General Terms and the related pre-contractual measures proposed by AdHub Media.
d) subject to optional consent, perform statistical analyses and market research, send informational and promotional materials, notify and invite to promotional initiatives by AdHub Media;
➢ The purpose referred to in letter e) is optional, and any refusal by the Publisher prevents them from benefiting from marketing activities (including direct and personalized marketing) by AdHub Media. These Processing activities are based on the Publisher’s free, specific, informed, and unambiguous consent, expressed through a statement or positive action (e.g., flag) on the Website. Consent may be withdrawn at any time by following the instructions in point 7 letter a) of this Privacy Notice.
e) Perform statistical analyses, market research, improve the presentation of the Service and the use of the Website by Publishers. Where possible, for this purpose, the Data Controller uses anonymized Personal Data.
➢ The Processing referred to in letter f) is based on the Data Controller’s legitimate interest, consisting of the benefit derived from offering Publishers services more aligned with their preferences during Website browsing, considering that it is also in the Publishers’ interest to use personalized services. For this reason, the Data Controller believes that the legitimate interest in developing and improving the Website and Service prevails over the Publishers’ right to privacy. Objection to this Processing (where it involves Personal Data and not anonymized data) may be exercised at any time by following the instructions in point 7 letter f) of this Privacy Notice.
The Data Controller collects Personal Data through the following methods:
a) Personal Data entered into the Website by Publishers: this includes Personal Data provided, by way of example but not limited to, for browsing, registering, and accessing the Service offered on the Website;
b) Personal Data explicitly communicated by Publishers through offline methods: this includes Personal Data provided, for example, to AdHub Media's customer service (in case of contact requests) or collected during events and/or initiatives organized by the Data Controller or communicated when accepting the General Terms;
c) Personal Data collected automatically by the Website: this includes Personal Data collected automatically by the Website through, but not limited to, Cookies.
Personal Data is processed by the Data Controller and/or by third parties, selected for reliability and competence, to whom it may be communicated where necessary or appropriate, provided that such parties are within the European Union. In particular, the Data Controller informs Publishers that Personal Data may be processed by, and/or communicated to:
a) employees and/or collaborators of the Data Controller;
b) third-party service providers necessary to ensure the functioning of the Website (e.g., hosting service providers);
c) third-party service providers necessary for the use of the Service (e.g., payment processors);
d) third-party IT and Website maintenance service providers;
e) third-party technicians providing Website navigation data analysis services;
f) subject to the Publisher's optional consent, third parties providing automated newsletter and/or any other type of commercial communication services, marketing, promotion, and analysis of consumption habits and choices.
Personal Data is retained by AdHub Media for the period strictly necessary to achieve the purposes for which it was collected, as indicated in point 3 above. In particular, unless the right to withdraw consent under point 7 letter a) and/or the right to object under point 7 letter f) is exercised:
a) for the use of the Service, the Data Controller retains Personal Data for the duration of the General Terms and for an additional 10 (ten) years from the termination of the Service;
b) for commercial purposes, the Data Controller retains Personal Data for a maximum period of 2 (two) years from the Publisher's consent.
In any case, the Data Controller is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to the information necessary to comply with legal obligations and to allow the Data Controller to establish, exercise, or defend a legal claim and/or in tax audits.
Upon expiry of these periods, the Data Controller will automatically delete the collected Personal Data or irreversibly anonymize it.
Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Privacy Notice, each Publisher has the right to:
a) with reference to the Processing referred to in point 3 letters d) and e), withdraw consent at any time without affecting the lawfulness of Processing, by sending an email to AdHub Media, exercising the opt-out in commercial communications, or by deleting the account directly on the Website (cf. Art. 7 of the Regulation);
b) request access to their Personal Data and information about the related Processing, as well as a copy in electronic format, unless the User and/or Publisher specifically requests otherwise (cf. Art. 15 of the Regulation);
c) request rectification and/or completion of their Personal Data without undue delay (cf. Art. 16 of the Regulation);
d) for specific reasons (e.g., unlawful Processing, withdrawal of consent, absence of the purpose for Processing), request erasure of their Personal Data without undue delay (cf. Art. 17 of the Regulation);
e) in specific cases (e.g., inaccuracy of Personal Data, unlawfulness of Processing, exercise of a legal claim), request restriction of Processing (Art. 18 of the Regulation);
f) with reference to the Processing referred to in point 3 letters d) and e), object at any time to the Processing of their Personal Data by sending an email to AdHub Media (cf. Art. 21 of the Regulation);
g) receive their Personal Data in a structured, commonly used, and machine-readable format, with the right to portability to another controller without hindrance (Art. 20 of the Regulation);
h) be informed by AdHub Media without undue delay of any breaches or unauthorized access by third parties to its systems containing Personal Data (so-called data breach - cf. Art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country where they reside, work, or where they believe their rights have been violated (cf. Art. 77 of the Regulation);
For further information on the terms and conditions for exercising the rights granted to the User, the latter may consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX:32016R0679, or contact AdHub Media as provided in point 2 of this Privacy Notice.
1. Third-party analytical Cookies
Google Analytics Cookies
a) Purpose:
these are Cookies provided by Google Inc. to monitor, in an anonymous and aggregated form, the statistical analysis of User traffic on the Publisher Website to adapt the Publisher Website to the results of such analysis, in line with the interests shown by the Users.
b) Data collected:
data related to the computer and the User's visit to the Publisher Website, which in no case allows AdHub Media to independently trace the User's Personal Data: (i) the domain from which the User accesses the Internet; (ii) the web address from which the User connected to the Website, if available; (iii) the date and time of connection to the Publisher Website, how long it lasted, and which pages were visited; (iv) the computer's operating system and the browser used by the User; (v) aggregated demographic details of Users accessing the Publisher Website.
c) Duration: session Cookies.
For further information on Google Analytics Cookies, the User may consult the following webpage: https://tools.google.com/dlpage/gaoptout.
2. AdHub Media profiling Cookies and third-party advertising Cookies
AdHub Media profiling Cookies:
a) Name: 4wnet.data.cookie.
b) Purpose: AdHub Media uses profiling Cookies to improve the commercial experience of Users by offering content tailored to their tastes and personal habits, as well as sending advertising communications related only to products that are most relevant to the User's interests.
c) Data collected: data related to the computer and the User's visit to the Publisher Website, to create a "navigation profile" of the User based on their searches and the most frequently visited sections of the Publisher Website.
d) Duration: 30 days.
e) Place of Processing: Italy.
Third-party advertising Cookies:
a) Purpose:
third-party advertising Cookies are provided by AdHub Media's partners, through links within the Advertising Campaign, to send information and commercial offers based on interests associated with the User's online activity. These Cookies do not personally identify Users.
b) Data collected:
data and information on the User's online preferences and/or habits, such as searches performed, page load frequency, or activity on other third-party websites.
c) Duration:
session and persistent Cookies.
For further information on third-party advertising Cookies, the User may consult the following webpages:
i) SSP (Sell Side Platform): Platforms used by AdHub Media to monetize advertising spaces aggregated on Publisher Websites
1. Freewheel: http://freewheel.tv/privacy-policy/
2. Improve: https://www.improvedigital.com/platform-privacy-policy/
3. Rubicon: https://rubiconproject.com/privacy-policy/?lang=it
4. Adform. https://site.adform.com/privacy-policy-opt-out/
5. OZ Digital: https://www.ozdigital.com/en/privacy-policy/
6. AOL: https://policies.oath.com/in/en/oath/privacy/index.html
7. Spotx: https://www.spotx.tv/privacy-policy/
8. Google: https://policies.google.com/privacy?hl=it&gl=it
9. Sublime: http://sublimeskinz.com/privacy-en
10. Criteo: https://www.criteo.com/privacy/
11. Onetag: https://onetag.net/privacy/
ii) DMP (Data Management Platform): platforms used by AdHub Media to create/manage Advertising Campaigns with audience-based targeting
1. Nugg.ad: https://nugg.ad/en/privacy/general-information.html
2. Nielsen VisualDNA: https://www.visualdna.com/privacy-policy/
3. Nielsen Exelate: http://www.exelate.com/privacy/services-privacy-policy/
4. Neustar: https://www.neustar.biz/privacy/opt-out
5. Navegg: https://www.navegg.com/en/privacy-policy/
6. Audience Rate: http://www.audiencerate.co.uk/privacy.html
7. Omnicom Media Group: http://www.omgitaly.it/pdf/Cookies_Policy_OMG.pdf
The Publisher must inform the User of the following.
The User may give their consent to the use of the Cookies described in the previous section 8 through the methods indicated on the Publisher Website (via an immediate pop-up information banner).
Consent may be modified at any time.
That said, with reference to all Cookies in the Service, the User may modify the related settings according to the methods provided in the control panels of the browser used, such as, by way of example:Furthermore, with specific reference to profiling and advertising Cookies (see point 8.2 of this Privacy Notice), in addition to using the tools provided by the browser to enable or disable individual Cookies, the Data Controller informs that if the User does not wish to receive targeted advertisements (i.e., based on their online behavior) displayed by the Data Controller or the third parties mentioned above or unknown to the Data Controller, they may disable the display of such targeted advertisements by clicking here www.youronlinechoices.com/it/le-tue-scelte and configuring the setting for AdHub Media with the appropriate ON/OFF button. The above procedure refers to the specific browser the User is using to access the Publisher Website at a given time. If the User uses multiple browsers to navigate the Internet and does not wish to see targeted advertisements delivered by AdHub Media under any circumstances, they must repeat the above operation for each browser.
- Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en
- Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
- Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
- Safari: https://support.apple.com/kb/PH19255?locale=it_IT
When the User disables the Data Controller's services, the latter places a technical Cookie in the User's browser to store their choice and respect it during subsequent online navigation. If this technical Cookie is deleted from the browser, the User must repeat the disabling procedure.
The above procedure will block only targeted advertisements delivered by the Data Controller and not those from any other third parties.