Terms of Use

Privacy Policy

Last updated July 19, 2018

1. What We Do

AdGinny is a white label advertising platform that offers fast, efficient and multifunctional online advertising solutions for publishers, media buyers, advertising networks and advertising exchanges.

We recognize the importance of protecting the privacy of individual-specific information collected from and about our website users. This Privacy Policy describes, how and why AdGinny collects non-personally identifiable data (anonymous data) from users and website visitors, publishers and end users of publisher sites to AdGinny (https://adginny.net), and how that data will be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and activities. AdGinny is committed to respecting the privacy of non-personal identifiable data and anonymous user data gathered.

This Privacy Policy constitutes an integral part of our website’s Terms of Use and is subject to the provisions thereof, including with respect to Limitation of Liability and governing law. We encourage you to read this Privacy Policy before you send or share Personal Information with us or use our website and to read it again when you return to it.

2. What Information We Collect

Information We Collect Automatically

Whenever you visit or interact with our website, AdGinny may use a variety of technologies that automatically or passively collect information about how the website is accessed and used (“Usage Information“). Usage Information may include, in part, browser type, operating system, device type, an estimate of your geographic location associated with your IP address, the page served, the time, referring URLs and other information normally transmitted in HTTP requests. This information helps us keep the website fresh and interesting to our users and tailor content to each visitor’s interests.

We also automatically collect the internet protocol (“IP“) address or other unique identifier (“Device Identifier“) for each computer, mobile device, technology or other device (collectively, “Device“) you use to access the website. A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers, and our computers identify each Device by its Device Identifier.

We use different technologies to collect Usage Information, including Device Identifiers. These may include, without limitation:


Cookies are small text files placed on a Device when the Device is used to visit the website. We may place cookies or similar files on your Device for security purposes, to facilitate website navigation and to personalize your experience while using it, including by better tailoring internal recommendations and promoted content to your preferences over time. For example, we may use your web browsing information to try to show you specific recommendations and sponsored recommendations that we think will be of particular interest to you.

Cookies allow us to collect technical and navigational information, such as browser type, time spent on the website and pages visited. Cookies may include a Device Identifier along with information about the particular type of content in which you have shown interest. Cookies also allow us to select which content is most likely to appeal to you and display that content while you are using our website.

If you would prefer not to accept cookies, you can do this by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

Log Files

For the correct operation of the service, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the website, to track users’ movements around the website and to gather demographic information about our user base as a whole.

Information You Provide To Us

In addition to the information we collect automatically, we may ask you to provide Personal Information when you sign up for our service(s) or otherwise communicate or interact with us. We may also ask you to provide other information about yourself, such as name, e-mail address and phone number. If you apply to become a customer of AdGinny, we may request additional information from you via customer application forms, insertion orders and other forms.

Our website includes social media features, such as the Facebook “Like” button or other similar features such as the “share this” button or interactive mini-programs that run on our website. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing such features.

3. How We Use The Collected Information

AdGinny uses the information we collect about and from you for a variety of business purposes, including for example:

• to verify your identity;

• to process applications and transactions;

• to conduct surveys and market research.

• to present you relevant content, marketing materials and advertisements, by analyzing your interests from the web pages you visit and online services that you use.

• to provide you with support and handle inquires.

• to enforce our terms of use and/or EULA.

• to improve the quality and functionality of the website, enhance your experience, create new services (including customized services), change/cancel existing content and services, or for other internal and statistical purposes.

• to comply with any applicable law and assist law enforcement agencies as required.

With respect to data collected via the AdGinny Platform, we may combine Non-Personal Information with data collected from other sources and disclose the Non-Personal Information and combined information to participating advertisers and ad networks so that they can determine whether to bid on ad inventory and in order to improve the relevance of the advertising presented to users. Examples of such data include: (a) country, city, and other geo-location details based upon the IP address of the user; (b) category and keyword information based upon the Publisher website URL; and (c) other data from advertisers and data providers that would help in ad targeting (e.g., an advertiser that wants to advertise to users who have previously visited the advertiser’s website).

4. Sharing Of Information

Except as provided in this Privacy Policy, we will not provide any of your Personal Information to any third parties without your specific consent.

However, we may disclose Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the website, to limit our legal liability and protect our rights or to protect the rights, property or safety of users of this website. We may also disclose your Personal Information to outside individuals and/or companies that help us bring you the products and services we offer and to create, operate, and maintain our website.

In addition, if we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information will likely be among the assets transferred.

We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:

Services On Our Behalf

In order to carry out your requests, to make various features, services and materials available to you through the website, and to respond to your inquiries, in certain instances we may share your Usage Information or Personal Information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals like an e-mail service provider to send e-mails on our behalf or a career provider to process employment applications on our behalf and other companies or individuals that host or operate our services and analyze data or provide customer service including via live chat software. We enter into agreements with all third parties who process Personal Information on our behalf to ensure that they do so in accordance with our instructions and applicable data protection laws.

Business Transfers

Your Personal Information may also be used by us or shared with our subsidiaries, affiliates and other entities in the family of companies controlled by AdGinny for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase a business or assets. If we purchase another entity or if another entity acquires us or all or substantially all of our assets, Personal Information, Usage Information, and any other information that we have collected about the users may be disclosed to such entity as part of the due diligence process and, if we or our assets are acquired, will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Disclosure

AdGinny may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier, to third parties to comply with certain legal obligations when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify, enforce or applicable terms or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of AdGinny, our customers or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5. Your Privacy Rights, Choice And Access

To the extent you have previously registered with us, you may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, or not to send you newsletters, e-mails or other communications, by following the removal instructions in the communication that you receive. Please note that upon registration with us, you agree to receive our newsletters and requests from our support service on your e-mail address.

If you wish to verify, correct, update or request the deactivation of your information collected through the website or service, you may edit your profile preferences or contact us at the above address or e-mail. In accordance with our routine record keeping, we may delete certain records that contain Personal Information. We will respond to requests for access within 30 days. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

AdGinny will retain your Personal Information for as long as needed to provide services to our customers. AdGinny will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6. Your Rights In The EEA

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you register with the website), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to United States.

7. Children

The website is not directed to children under 13. We do not knowingly collect Personal Information from anyone under 13 years of age. If we determine upon collection that a user is under 13, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

8. Security Of Your Information

We maintain tight controls over all the data we collect, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure. When you enter sensitive information (such as login credentials) we encrypt that data via SSL encryption. Please remember that, unfortunately, the transmission of information via the Internet is not completely secure, so although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

AdGinny uses generally accepted industry security standards to protect data. We retain identifiable data, which is directly collected for purposes of serving content to end-users, for twenty-four (24) months from the end-user’s last interaction with our website, after which time we de-identify the data by removing unique identifiers or aggregating the data. We retain aggregated data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary.

9. Opt-Out and Links To Third-Party Sites

AdGinny platform supports opt-out function by default, though, please note that our website may contain links to other websites that we do not own or operate. This includes links from customers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other websites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies.

AdGinny policies do not extend to anything that is inherent in the operation of the Internet, which is beyond our control. Remember that whenever you give out Information online, that information may be collected and used by people you do not know.

10. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of California, USA. You agree to submit any dispute arising out of your use of this Website to the exclusive jurisdiction of the courts of California.

11. Changes To Privacy Policy

Please note, we may modify and revise this Privacy Policy from time to time. If we make any material changes, we will place a prominent notice on the website prior to the change becoming effective. You should check back here periodically to see if the Privacy Policy has been updated. We will always show the date of the latest modification of the Privacy Policy at the top of the first page so you can see when it was last revised.

12. Contact Us

We regularly review our compliance with this Privacy Policy. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed via e-mail to smukato@gmail.com, nick.adginny@gmail.com.