ADAGIO PRIVACY POLICY

Adagio Privacy Policy

Latest version: August 27th, 2024

ABOUT US

Our Corporate Details

The company Onfocus SAS whose headquarters are located at 450 Rue Baden Powell, 34000 Montpellier, FRANCE is represented by Mr Anh-Tuan GAI in his capacity as President and cofounder of the company.

Onfocus SAS operates under the trade name Adagio which is used in Onfocus’ privacy policy (hereafter “Adagio’s Privacy Policy” or “our Privacy Policy” or “Privacy Policy”).

Our Core Business

Adagio is a fully transparent advertising monetization platform, Supply Side Platform (hereafter “Adagio SSP”), providing programmatic buyers with access to high quality Publishers’ inventory. As an independent, publisher-focused SSP, our company has been reinventing digital advertising by switching from media to user attention trading and reaching an unprecedented level of performance. Adagio SSP is able, notably, to predict which impression has a chance to be seen and for how long.

Our data protection officer

Adagio has appointed a data protection officer (hereafter “Adagio’s DPO” or “our DPO”) who is responsible for ensuring that the company complies with all regulations in force in term of data protection and privacy, as well as with professional standards and codes of conduct starting with the latest version of the Transparency and Consent Framework (hereafter the “TCF”) of the Interactive Advertising Bureau (IAB). The “TCF” is a key industry standard that imposes, for registered companies, to comply with technical standards and policies adjusted to their subscription on the IAB Global Vendor List (hereafter the “GVL”). Adagio is registered on the TCF GVL as a vendor and complies with the latest associated requirements.

Should you have any questions related to Adagio’s data protection and Privacy Policy or should you want to uphold your rights as a data subject, please contact Adagio’s DPO by email at [email protected].

Our Ethos

Adagio attaches great importance to the respect of your privacy and to the security as well as the confidentiality of your data. In this context, Adagio adheres to the latest version of the TCF called the TCF V 2.0.

Our Privacy Policy expresses our commitment to data subjects (hereafter the “Users”) as well as to our business partners. In order to provide you with clear and easily accessible information on all the personal data (hereafter “Personal data”) processing carried out by Adagio, we have established a Privacy Policy dedicated to visits of our website for our business partners and a Privacy Policy that covers the performance of Adagio SSP dedicated to Users.

ADAGIO WEBSITE PRIVACY POLICY

This Privacy Policy applies to Personal Data we collect through our website. It details the measures undertaken by Adagio to protect its business partners and prospects’ Personal Data.

To access the Privacy Policy for Users including data that Adagio collects when you use the Adagio SSP, please click here.

1 - WHAT DATA DO WE COLLECT AND HOW ARE THEY COLLECTED?

1.1 Information you provide to us

Certain parts of our website may ask you to provide us with personal information about you on a voluntary basis. For instance, Adagio may ask you to provide your identifiers or contact details when you fill in our “Get in Touch” forms. In this context, the personal information we collect may include your name, address, telephone number or email. It may also include professional information such as your job title as well as the nature of your request.

1.2 Information we collect automatically

By using our website, Adagio may collect certain information automatically. Some of this information may be collected by using cookies or similar tracking technologies to perform Adagio's website browsing.

Some of this information may include, on the top of the technical needed tracking data, identifiers or IP addresses considered as “Personal Data”.

2- HOW DO WE USE YOUR DATA?

The data is used for sharing information about Adagio services or providing you with information you requested.

The data collection might use cookies or similar technologies for the purposes of audience analysis and statistical measures, enabling the improvement of the performance and/or the relevance of Adagio communication with our prospects or partners like you.

3- ON WHAT GROUND DO WE PROCESS YOUR DATA?

The personal data collected is exclusively processed on the ground of your consent, either when you provide information to us, or when you agree such information to be collected automatically through the use of cookies or similar tracking technologies.

4- HOW DO WE STORE YOUR DATA?

Adagio only retains information necessary to achieve the purposes aforementioned, in the limit of 13 months after your last interaction with Adagio’s website.

5- HOW DO WE SECURE YOUR DATA?

Adagio is committed to ensure the confidentiality of the data collected and to prevent unauthorized third parties from viewing, using, disclosing, modifying, damaging or destroying the said data. Adagio has an extremely solid and documented security policy that can be made available upon request by sending an email at [email protected].

6- HOW DO WE SHARE YOUR DATA?

In order to allow Adagio to operate its website, business operations, the data collected might be transferred to countries outside of the European Union to the following subcontractors.

In this case, Adagio guarantees that the right level of data protection is implemented by such subcontractors. When the country that isn’t part of the European Union and in which is located the subcontractor is not subject to an adequacy decision, we guarantee the level of protection of your data by implementing appropriate safeguards through contractual commitments binding the data recipients to us, or by the adhesion of the third party to Binding Corporate Rules.

7- WHAT ARE YOUR DATA PROTECTION RIGHTS?

As a User, you have rights related to the processing of your data by Adagio. You can exercise those rights at any time by contacting Adagio by sending an email at [email protected]. We will respond to your request as soon as possible, provided that you transmitted a proof of your identity, and the necessary information to process your request.

Your rights as a User are guaranteed by the GDPR, articles 12 to 22, and include among others:

The right to access – You have the right to request Adagio for copies of your personal data.
The right to rectification – You have the right to request that Adagio correct any information you believe is inaccurate.
The right to erasure – You have the right to request that Adagio erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Adagio restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Adagio’s processing of your personal data, under certain conditions.

Moreover, you have the possibility to oppose the deposit of cookies and to access the exhaustive list of your cookies by configuring your browser. These links will help you to manage your cookies, depending on your browser : Chrome , Mozilla , Opera or Safari .

You can file a complaint with the relevant supervisory authority (data protection authorities in Europe such as the CNIL in France).

8- CHANGES TO THIS PRIVACY POLICY

This Policy may be subject to modifications. Any change of the rules will be accessible on this page as soon as it comes into force.

ADAGIO USERS PRIVACY POLICY

This Privacy Policy details the measures Adagio undertakes to ensure the protection of the User’s Personal Data with regards to its activity to predict which impression has the best chance to be seen and how long.

To access to the Privacy Policy that only applies to personal information Adagio collects on its website, please click here.

By browsing this Privacy Policy page, the end user can access information on:

WHAT DATA DO WE COLLECT?
HOW DO WE COLLECT YOUR DATA?
HOW WILL WE USE YOUR DATA?
ON WHAT GROUND DO WE PROCESS YOUR DATA?
HOW DO WE STORE YOUR DATA?
HOW DO WE SHARE YOUR DATA?
WHAT ARE YOUR DATA PROTECTION RIGHTS?
HOW DO WE SECURE YOUR DATA?
CHANGES TO THIS PRIVACY POLICY.

1- WHAT DATA DO WE COLLECT?

As part of our business as a SSP, Adagio collects and uses several categories of data that are strictly necessary in order to provide its services.

Specifically, the information Adagio collects generally includes:

Your IP address. Adagio needs your IP address in order to provide its services. Adagio only uses your complete IP address if you agreed to it; otherwise, only a fully anonymized version of the IP address will be used.
Your approximate location. Adagio also uses User’s approximate location such as the country or the city location based on the User’s IP address. The collection of the User’s IP address is only processed to locate you geographically without other precise location than your country for your city. Adagio does not perform any precise geolocation and does not collect the GPS Users’ position.
The consent ID. This information allows Adagio to know that you, as a User, share your proper and updated consent to the data controller in order to provide our service with the right legal basis.
The context Analysis Data. This information includes several technical information on the device you use, the “user agent” containing information related to your browser, your exploitation system, the page types accessed, and the size of the screen.
Your User ID. This information is a string that allows Adagio to identify Users in order to unify all related events while we provide our service.
The View Count Data. This information includes the number of times you accessed a website on your browser.

Even though these different categories of data are exclusively non-nominative, please note that they might fall under the category of Personal Data since they are precise enough (as such or in combination with one another) in order to relate to an identified or identifiable user.

2- HOW DO WE COLLECT YOUR DATA?

Adagio SSP collects some data including Personal Data listed above directly by using cookies or similar technologies, but Adagio receives most of the data from the publishers (hereafter the “Publishers”) as part of a contractual relationship. Publishers are responsible for the Consent Management Platforms (Hereafter the “CMP”) settings and the Users’ consents collection.

Most of the time, Adagio is acting as data processor of Publishers (websites’ publishers or media sellers acting on behalf of Publishers). A list of the main Publishers from which Adagio receives its data is accessible here.

In the digital advertising sector, Publishers use SSPs’ technologies to better monetize their advertising spaces. In that context, there are exclusive deals between the Publishers and technical providers such as Adagio even on an identified inventory in specific agreements such as the private deals. Therefore, the list of the Adagio Publishers might change on a regular basis and cannot be exhaustive because of the media selling business structure.

3 - HOW WILL WE USE YOUR DATA?

Adagio markets technological solutions for attention trading based on proprietary tools allowing to predict the exposure of advertising spaces and how long each advertising impression will be viewable. These innovative solutions have, in particular, the benefits of optimizing the monetization of Publishers' advertising spaces.

In that context the data is used for the following purposes:

to perform Adagio SSP services to Publishers;
to improve Adagio technology;
to perform in advertising and predict the attention on an ad.

Adagio is authorized to perform on behalf of Publishers all processing necessary to execute the agreement when it acts as data processor of Publishers.

The nature of the operations carried out on the collected data listed above all processings necessary for the execution of the agreement and in particular the collection, the recording, the storage, the adaptation, the modification, the extraction, the consultation, the use, the communication by transmission, the diffusion or any other form of making processing available such as the reconciliation, the interconnection, the blocking, the erasure or destruction of the Personal Data.

4- ON WHAT GROUND DO WE PROCESS YOUR DATA?

Most of the time, Adagio operates its SSP as a data processor, based on the instructions of its Publishers. In this case, Publishers are accountable for the establishment of an appropriate legal basis for the processing of the data. You can find this information in their own Privacy Policy available on their website.

In any case, Adagio processes the Personal Data of the User on the legal ground of its consent.

5- HOW DO WE STORE YOUR DATA?

Adagio doesn’t store most of the processed Personal Data. These data are used, and then immediately transferred, without being stored by Adagio.

The only Personal Data that Adagio stores is the View Count data. This data is stored in the local storage of the User it relates to, and is stored for a maximal duration of 120 days.

6- HOW DO WE SHARE YOUR DATA?

6.1 Data shared with Third Parties

Adagio may share information, including Personal Data, with trusted third parties that provide services for Adagio, such as hosting and internet connectivity. Adagio may also share data with trusted subsequent data processors such as Demand Side Platforms.

6.2. Data transfers

The Data we collect may be processed by such third parties that are located outside the European Union. In this case, Adagio guarantees that the right level of data protection is implemented by any third party such as subcontractors around the world. When the country that isn’t part of the European Union and in which is located the third party is not subject to an adequacy decision, we guarantee the level of protection of your data by implementing appropriate safeguards through contractual commitments binding the data recipients to us, or by the adhesion of the third party to Binding Corporate Rules.

7 - WHAT ARE YOUR DATA PROTECTION RIGHTS?

As a User, you have rights related to the processing of your data by Adagio. You can exercise those rights at any time by contacting the Publisher in charge of collecting your consent, or contacting Adagio by sending an email at [email protected]. We will respond to your request as soon as possible, provided that you transmitted a proof of your identity, and the necessary information to process your request.

Your rights as a User are guaranteed by the GDPR, articles 12 to 22, and include among others:

The right to access – You have the right to request copies of your personal data.
The right to rectification – You have the right to request the rectification of any information you believe is inaccurate.
The right to erasure – You have the right to request the erasure of your personal data, under certain conditions.
The right to restrict processing – You have the right to request the restriction of the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to the processing of your personal data, under certain conditions.

You can file a complaint with the relevant supervisory authority on the basis of your rights (data protection authorities in Europe such as the CNIL in France).

8- HOW DO WE SECURE YOUR DATA?

Adagio implements all the necessary security measures to protect Users’ information from any unauthorized access, damage, disclosure or destruction of the data we have collected. Indeed, Adagio places particular importance on the security of the User’s Personal Data by using technologies that provide security in line with the most demanding standards, using SSL, hashing/encryption and firewall technologies. We do everything we can to ensure the confidentiality of collected data and to prevent unauthorized third parties from viewing, using, disclosing, modifying, damaging or destroying said data.

9- CHANGES TO THIS PRIVACY POLICY

Adagio may update this Privacy Policy from time to time in order to reflect, for instance, changes to our practices or for other operational, legal or regulatory reasons. If we make material changes to this policy, we will notify you of any material changes by posting the revised policy on this website, and where necessary, by any other means required by applicable law.