Effective January 13, 2021
If you have any questions or concerns about our Personal Information use, please contact us using the contact details provided at the end of Section 5.
Those policies will govern such interactions to the extent we provide you with notice of different or additional privacy policies.
- The Basics
A. About Us
AdCentral is an online marketing platform operated by Dev It LLC, a company headquartered in the State of Virginia in the United States (“we,” “us,” “our,” and “AdCentral”).
Our Service enables our Members to, among other things, automate marketing.
B. Key Terms
“Affiliate” means an entity that directly or indirectly Controls, is Controlled by, or is under common Control with an entity.
“Control” means an ownership, voting, or similar interest representing fifty percent (50%) or more of the total parts then outstanding of the entity in question. The term “Controlled” shall be construed accordingly.
“Member” means any person or entity that is registered with us to use the Service.
“Mobile App(s)” means any one or all of the AdCentral applications available for Members to use on their mobile devices.
“Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
“Visitor” means, depending on the context, any person who visits any of our AdCentral Sites, offices, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.
“you” and “your” means, depending on the context, either a Member or a Visitor.
- Privacy for Members
This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Service. If you are not a Member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Members and potential Members.
A. Information We Collect
The Personal Information that we collect depends on the context of your interactions with AdCentral, your AdCentral account settings, the products and the features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:
(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you sign up for an AdCentral account and use the Service, consult with our customer service team, send us an email, integrate the Service with another website or Service (for example, when you choose to create an account with us), or communicate with us in any other way.
This information may include:
Business contact information (such as your name, job title, organization, location, phone number, email address, and country);
Marketing information (such as your contact preferences);
Troubleshooting and support data (which is data you provide or otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or Service you are using related to your help inquiry); and
Payment information (including your credit card numbers and associated identifiers and billing address).
Service Usage Data may include:
Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection. If you are using our App, we may also collect information about the network associated with your device, your device’s operating system or platform, the type of device you use, your device’s name and unique device ID, and information about the features of our App that you accessed.
Log data: Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
Usage Data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Service. If you are using our App, we may collect information about how often you use the App and other performance data. This information allows us to improve the content and operation of the Service, and facilitate research and analysis of the Service.
(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners.
Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.
B. Use of Personal Information
We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:
To bill and collect money owed to us by you to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Service. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number or PayPal account. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.
To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service. For example, if you use our Apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted into these push notifications and no longer want to receive them, you may turn them off through your operating system.
To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.
To prosecute and defend a court, arbitration, or similar legal proceeding.
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
To provide, support, and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For further information about how we share your information, refer to Section 5 below.
To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience in reliance on our legitimate interests in administering the Service and providing certain features.
C. Third-Party Integrations
D. Cookies and Tracking Technologies
Our third-party partners and we may use various technologies to collect and store Service Usage Data when you use our Service (as discussed above), and this may include using cookies and similar tracking technologies, such as pixels, web beacons, and if you use our Apps, through our SDKs deployed on your mobile device.
- Privacy for Visitors
This section applies to Personal Information that we collect and process when you visit the AdCentral Sites. In our business’s usual course, such as in connection with our recruitment, events, sales, and marketing activities or when you visit our offices. In this section, “you” and “your” refer to Visitors.
A. Information We Collect
(i) Information you provide to us on the AdCentral Sites or otherwise: Our AdCentral Sites offer various ways to contact us, such as through form submissions, email, or phone, to inquire about our company and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe to marketing, apply for a role with AdCentral, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, if you visit our offices (where you will be required to register as a visitor and provide us with certain information that may also be shared with our service providers) or via a phone call with one of our sales representatives. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.
The Personal Information we collect may include:
Business contact information (such as your name, phone number, email address, and country);
Professional information (such as your job title, institution, or company); Nature of your communication;
Marketing information (such as your contact preferences); and
Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.
The information we collect automatically includes:
Device information: such as your IP address, your browser, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called “exit page”), information about other websites you have recently visited and the web browser you used (software used to browse the internet) including its type and language)
Usage Data: such as information about how you interact with our emails, AdCentral Sites, and other websites (such as the pages and files viewed, searches, operating system, and system configuration information, and date/time stamps associated with your usage).
B. Use of Personal Information
We may use the information we collect through our AdCentral Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:
To provide, operate, optimize, and maintain the AdCentral Sites.
To send you marketing information, product recommendations, and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions, or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
For recruitment purposes, if you have applied for a role with AdCentral.
To respond to your online inquiries and requests and to provide you with information and access to resources or services that you have requested from us.
To manage the AdCentral Sites and system administration and security.
To manage event registrations and attendance, including sending related communications to you.
To register visitors to our offices for security reasons and to manage non-disclosure agreements that visitors may be required to sign.
To improve the navigation and content of the AdCentral Sites.
To identify any server problems or other IT or network issues.
To process transactions and to set up online accounts.
To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
To help us provide, improve, and personalize our marketing activities.
To facilitate the security and continued proper functioning of the AdCentral Sites.
To carry out research and development to improve our AdCentral Sites, products, and services.
To conduct marketing research, advertise to you, provide personalized information about us on and off our AdCentral Sites, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.
To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends, and expanding our business activities in reliance on our legitimate interests.
To cooperate with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws to the extent, this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our AdCentral Sites and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.
C. Public Information and Third-Party Websites
Blog. We have public blogs on the AdCentral Sites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.
Social media platforms and widgets. The AdCentral Sites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our AdCentral Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our AdCentral Site. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
D. Cookies and Tracking Technologies
E. Other Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by visiting this page or by emailing us.
You may also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
- General Information
A. How We Share Information
Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.
In connection with our Service, we also use a third-party service provider, Twilio, Inc. We use Twilio’s API, which allows us to build features into our AdCentral application to enable us to communicate with our Members through texting and calling, and their “Authy” product, which we use for two-factor authentication for our application. If you are a Member, Twilio may need to collect and process certain Personal Information about you as a controller to provide such services. To learn more about Twilio’s privacy practices, please visit https://www.twilio.com/legal/privacy
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(v) Any other person with your consent.
We may also share anonymized, aggregated information with selected third parties for statistical purposes.
B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)
If you are located in the EEA or UK, 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.
If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract 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.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us.
C. Your Choices and Opt-Outs
Members and Visitors who have opted in to our marketing emails can opt-out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt-out of these messages unless you cancel your AdCentral account.
D. Our Security
We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Security page available here. If you have any questions about the security of your Personal Information, you may contact us at [email protected]
AdCentral uses Google authentication service, which means we cannot see a Member’s password. We cannot resend forgotten passwords either.
E. International Transfers
(i) We operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a Data Processing Agreement available here.
F. Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:
Whether we have a legal or contractual need to retain the data. Whether the data is necessary to provide our Service.
Whether our Members have the ability to access and delete the data within their AdCentral accounts.
Whether our Members would reasonably expect that we would retain the data until they remove it or until their AdCentral accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
G. California Privacy
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Members with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to its Members, AdCentral acts as a “service provider” under the CCPA, and our receipt and collection of any consumer Personal Information is completed on behalf of our Members in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Member with whom you have a direct relationship.
Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.
H. Do not Track
I. Changes to this Policy
J. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:
Dev It LLC d/b/a AdCentral
1818 Library St, Suite 500
Reston, VA 20190 USA