AwesomeAds Marketplace Privacy Policy

Last updated: 24 April 2023

Welcome to the AwesomeAds Marketplace Privacy Policy

Contents

1. About us
2. About this privacy policy
3. General information about how we process Users’ data
4. What do we do with End Users’ data?
5. What do we do with Authorised Users’ data?
6. What do we do with general enquiry and subscribers’ data?
7. How do we share Users’ data?
8. How do we transfer Users’ data internationally?
9. How do we secure Users’ data?
10. Your legal rights
11. Location-specific privacy rules
12. Changes to this privacy policy

1. About us

About SuperAwesome

SuperAwesome Trading Limited (referred to herein as SuperAwesome, us, our or we) is a private limited company incorporated in England (Company Number: 03885555), having its registered office at Octagon Point, 5 Cheapside, London EC2V 6AA, United Kingdom.

About AwesomeAds Marketplace

AwesomeAds Marketplace is an ad server that delivers advertising (Ads) to websites and mobile applications appropriate for children. AwesomeAds Marketplace serves Ads that are placed using contextual information such as broad-based location (i.e. country or U.S. State, as applicable) and the content of the website or app on which the Ad is placed.

AwesomeAds Marketplace and the Customer management dashboard (Dashboard) are designed for use by SuperAwesome’s customers, who comprise advertisers and their agencies (who wish to promote goods and services) and publishers (who wish to earn revenue from advertising placed on their apps and sites) (Customers).

AwesomeAds Marketplace’s proprietary contextual targeting technology has been certified compliant with COPPA by three FTC-approved COPPA Safe Harbor Programs. For more information, see COPPA-compliant contextual targeting technology below.

Our contact details

SuperAwesome works hard to ensure that the processing of personal data is carried out fairly and lawfully. If you have any questions, need information or require assistance, please contact us at:

Attn: Chief Privacy Officer

SuperAwesome Trading Limited, Octagon Point, 5 Cheapside, London EC2V 6AA, United Kingdom

Email: [email protected] 

Alternatively, if you are located inside the European Economic Area (EEA) you can contact our EEA representative at:

Attn: SuperAwesome GDPR Representative

Mason Hayes and Curran Professional Services Limited, South Bank House, Barrow Street, Dublin 4, Ireland

Email: [email protected]

2. About this privacy policy

Purpose of this privacy policy 

This Privacy Policy explains how we (SuperAwesome) collect, process, share and transfer your personal data when you use AwesomeAds Marketplace or when you view or interact with an Ad served by the AwesomeAds Marketplace.

It is important that you read this Privacy Policy so that you are fully aware of how and why we are processing your data.

By using AwesomeAds Marketplace, you confirm that you have read and understood this Privacy Policy.

This Privacy Policy applies only to AwesomeAds Marketplace. It does not apply to any other site or service offered by SuperAwesome or to any third-party websites or mobile applications to which AwesomeAds Marketplace may link.

Terms used in this privacy policy

These terms relate to AwesomeAds Marketplace and its users:

• Dashboard means the AwesomeAds Marketplace Customer management dashboard
• Customers means SuperAwesome’s customers, who comprise advertisers and their agencies (who wish to promote goods and services) and publishers (who wish to earn revenue from advertising placed on their apps and sites)
• Authorised User means an individual who uses the Dashboard to manage advertising campaigns on behalf of a Customer 
• End User means a person, typically a child, who uses a website or mobile application on which an Ad is delivered using AwesomeAds Marketplace 
• child means a person below the age of 16 
• Users means Authorised Users and End Users

These terms relate to Users’ data and how AwesomeAds Marketplace interacts with it:

• GDPRs means the General Data Protection Regulation (EU) 2016/679 and the United Kingdom General Data Protection Regulation
• GDPR-K means the additional requirements under the GDPRs that apply to websites and apps whose audience is primarily kids
• COPPA means the US Children’s Online Privacy Protection Act 
• data means information about a User, both technical data and personal data

• technical data means data observed from a User’s device. For example, user agent data, operating system (OS), internet protocol (IP) address, and timestamp
• personal data

  means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data includes, for example, name, date of birth, address, email address, and IP address

• processing or process

  any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

Note that some data elements can be both technical data and personal data (for example, IP address).

3. General information about how we process Users’ data

This section sets out how we process the data of all Users, including that of child End Users.

Our right to process Users’ data

SuperAwesome is a data controller (as defined in the GDPRs) which may process the personal data of Users in AwesomeAds Marketplace to support Customers to operate safe Ad campaigns in accordance with applicable legal requirements.

We only process Users’ data when we have a legal basis to do so, in any of the following circumstances:

• Where it is necessary for us to enter into, or perform a contract with, a Customer
• Where it is necessary for our legitimate interests, and the Users’ interests and fundamental rights do not override those interests
• Where we need to comply with a legal obligation

Note that we may process a User’s data for more than one lawful basis, depending on the specific purpose for which we are using their data. For more information, contact us at [email protected]. 

Legitimate interests

When we refer to our legitimate interests we mean the interest of our company (SuperAwesome) in conducting and managing our business to enable us to give Users the best service/product and the best and most secure experience.

We make sure we consider and balance any potential impact (both positive and negative) on Users and Users’ rights before we process their data for our legitimate interests. We do not process a User’s data for activities where our interests are overridden by the impact on the User (unless we have their consent or are otherwise required or permitted to by law). 

For further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities, contact us at [email protected].

Special category data

AwesomeAds Marketplace does not process any special categories of personal data (as defined in the GDPRs) about Users, including for example information about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, and genetic or biometric data.

Change of purpose

We will only process a User’s data for the purposes for which we originally intended, unless we reasonably consider that we need to process it for another reason and that reason is compatible with the original purpose. 

For an explanation of how the processing of your data for a new purpose is compatible with the original purpose, please contact us at [email protected].

User consent

We may process a User’s data without their knowledge or consent, in compliance with the rules in Our right to process Users’ data, where this is required or permitted by law.

4. What do we do with End Users’ data?

An End User is a person, typically a child, who uses a website or mobile application on which an Ad is delivered using AwesomeAds Marketplace.

How do we safeguard children’s privacy?

AwesomeAds Marketplace enables publishers to receive Ads secure in the knowledge that their users – including children – are protected from the risks associated with online profiling and interest-based targeting, and that they (the publishers) are serving Ads in compliance with COPPA and GDPR-K.

AwesomeAds Marketplace does this by deploying a proprietary process specifically designed to minimise our interaction with End User data, and to prevent such interaction by third parties involved in delivering Ads. This process entails the use of de-identified data when delivering Ads and monitoring their performance. For more information, see How do we process End Users’ data?

All Ads delivered by AwesomeAds Marketplace carry the SuperAwesome ‘SAFE AD’ watermark:

COPPA-compliant contextual targeting technology

AwesomeAds Marketplace’s proprietary contextual targeting technology is certified under the following COPPA Safe Harbor Programs approved by the US Federal Trade Commission (FTC):

the kidSAFE Seal Program:

the ESRB Privacy Certified Program:

the CARU COPPA Safe Harbor Program:

The COPPA Safe Harbor Programs do not certify individual ads or ad campaigns.

The COPPA Safe Harbor Programs monitor and audit the AwesomeAds Marketplace contextual targeting technology for compliance with COPPA. 

What End User data do we process?

The data we process from End Users is limited to specific technical data relating to the device on which the End User is viewing and engaging with an Ad served by AwesomeAds Marketplace. We refer to this data as Device Data. 

Device Data is defined as follows:

• If an End User sees the Ad on a mobile app, their Device Data consists of the device’s user agent string, IP address and the app’s BundleID (e.g. “com.acme.bestgamever”) from the End User’s mobile device 
• If an End User sees the Ad on a web browser, their Device Data consists of the device’s user agent string, IP address and the site’s web domain address (e.g. “www.website.com”) where the Ad is shown

How do we process End Users’ data?

The only End Users’ data we process is Device Data. In all cases we are strong advocates of data minimisation with regard to Device Data – even if some of that data is not personal data. 

We process End Users’ Device Data as follows:

1. We generate a de-identified Marker

We observe the Device Data momentarily, and only in order to immediately transform it into a temporary custom identifier called a Marker. A Marker is a temporary, unique, one-way hashed value that cannot be reverse engineered to identify a particular individual.

Our Marker was designed specifically to enable AwesomeAds Marketplace to deliver Ads without SuperAwesome or any third party storing the personal data of End Users, which could be used to build online profiles for behavioural advertising, or other purposes that are not in compliance with data privacy laws regarding children. 

By using a Marker, we do not need to retain or process Device Data in its original form. 

To create the Marker:

• We obfuscate the Device Data by injecting randomised characters into it and then run the resultant string through an algorithm which creates the Marker 
• The Device Data is not stored by SuperAwesome and is used only within the SDK
• We discard the Marker when each Ad campaign has ended, or at month end, whichever occurs first

2. Third party Ad measurement

We may provide limited third-party access to Device Data for Ad measurement purposes, as explained in How do we share Users’ data?

What is our legal basis for processing End Users’ data?

The following tables outline the purposes for which we may process End Users’ data, the legal bases we rely on to do so, and what our legitimate interests are, where appropriate. 

Type of data processed by AwesomeAds Marketplace	Purpose of processing data	Lawful basis for processing data
End Users’ Device Data	Momentarily observed on the End User’s device to create a Marker for the purpose of facilitating an Ad request to AwesomeAds Marketplace	Legitimate interests to deliver safe Ads to End Users (who may be children)

Type of de-identified data processed by AwesomeAds Marketplace	Purpose of processing de-identified data
Marker	For AwesomeAds Marketplace to deliver Ad requests and for capping the number of times an End User sees the same Ad (i.e. frequency capping)

How long do we retain End Users’ Device Data?

We retain the following data elements indefinitely for reporting purposes:

• language
• device type
• web domain

These elements cannot be used to identify an individual. 

There is no permanent retention of End Users’ personal data within AwesomeAds Marketplace (or by SuperAwesome). An End Users’ Device Data is observed by us only momentarily, as further explained in How do we process End Users’ data? above.

5. What do we do with Authorised Users’ data?

An Authorised User is an individual who uses the Dashboard to manage advertising campaigns on behalf of our Customers.

What Authorised User data do we process?

To enable an Authorised User to access the Dashboard, we process their first name, last name, corporate email address, and Dashboard password. 

When an Authorised User interacts with the Dashboard, we process technical data about their equipment, browsing actions and usage patterns on the Dashboard. We collect this data by using cookies, server logs and other similar technologies. 

We process aggregated data such as statistical or demographic data of Authorised Users to monitor and improve the performance and features of the AwesomeAds Marketplace. 

What is our legal basis for processing Authorised Users’ data?

This table outlines the purposes for which we may process certain types of Authorised Users’ data, the legal bases we rely on to do so, and what our legitimate interests are, where appropriate. 

When we process Authorised Users’ data	Type of data processed by AwesomeAds Marketplace	Purpose of processing data	Lawful basis for processing data
When an Authorised User creates a Dashboard account	First name, last name, corporate email address and Dashboard password	To enable Authorised Users to use the Dashboard	The performance of our contractual obligations with Customers
When an Authorised User interacts with the Dashboard	IP address, login data, browser type and version, time zone setting, country and language, browser plug-in types and versions, operating system	To use data analytics to improve Customer relationships and Authorised User experiences	Necessary for our legitimate interests to operate, maintain and improve AwesomeAds Marketplace

How long do we retain Authorised Users’ data?

SuperAwesome retains personal information for as long as necessary to fulfil the purposes we collected it for, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements or protecting our rights. 

To determine the appropriate retention period for Authorised Users’ data, we consider:

• the amount, nature and sensitivity of the data
• the potential risk of harm from unauthorised use or disclosure of the data
• the purposes for which we process the data and whether we can achieve those purposes through other means
• applicable legal, regulatory, tax or accounting requirements

We only retain the data of Authorised Users for the life of the Customer relationship with SuperAwesome or until deletion is requested either by the Customer or the Authorised User, or for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 

We may retain an Authorised User’s data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with the Customer or the Authorised User.

Marketing

We do not normally send marketing materials to Authorised Users unless they have opted in to receive marketing from SuperAwesome through other channels. From time to time, Authorised Users receive service information updates via the Dashboard. 

Cookies

We use Google Analytics on the Dashboard. Google Analytics places a cookie on Authorised Users’ devices. As an Authorised User, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. 

If you disable or refuse cookies, some parts of the Dashboard may become inaccessible or not function properly.

6. What do we do with general enquiry and subscribers’ data?

When someone enquires about our products or services, subscribes to our service or publications, or gives us feedback, we process the personal data which they have provided (e.g. name and email address) to respond to them.

7. How do we share Users’ data?

Sharing Users’ data with third-party providers

SuperAwesome uses a small number of third-party service providers to help us provide the AwesomeAds Marketplace to Users. Some of these providers may process Users’ data on our behalf. 

For example:

• We use a third party to host AwesomeAds Marketplace
• We use third party tools to help us better understand how Customers and Authorised Users navigate across the Dashboard 
• We use service providers to support our internal operations, and who may process Device Data to measure the effectiveness of an Ad. For example, to support fraud detection (by determining invalid traffic such as bots), verification of impressions, and measuring how much of an Ad was ‘viewable’ 

We enter into contractual arrangements with our service providers to ensure that they are only processing your data in a lawful manner and strictly for the foregoing purposes. It may not be used or shared for any other purposes, including for behavioural advertising or to amass a profile on a User.

We maintain a current list of providers here. To learn more about how our third-party data processors use Users’ data, please refer to their privacy policies.

Sharing Users’ data within SuperAwesome

We may share a User’s data within the SuperAwesome group of companies and other third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may process a User’s data in the same way as set out in this Privacy Policy.

Sharing Users’ data for other reasons

We may disclose a User’s data for any of the following reasons: 

• in the good faith belief that we are required to do so by law
• if doing so is reasonably necessary to comply with legal process
• to permit us to pursue available remedies, including commencing or responding to any claims
• to enforce the terms and conditions of AwesomeAds Marketplace
• to protect the rights, property, or personal safety of SuperAwesome or the public
• to prevent other illegal activity
• for risk management purposes

8. How do we transfer Users’ data internationally?

We may transfer Users’ data in the following ways:

• We share Users’ data within the SuperAwesome group of companies. This involves transferring Users’ data outside the UK and EEA.
• Some of our third-party data processors are based outside the UK and EEA so their processing of Users’ data may involve a transfer of Users’ data outside the UK and EEA.

Whenever we authorise a transfer of Users’ data outside of the UK and EEA, we ensure a similar degree of protection is afforded to it by using specific contracting frameworks approved by the UK Government and European Commission which give personal data the same protection it has in the UK and EEA. If you require further information on the specific mechanism used by us when transferring Users’ data outside of the UK or EEA, please contact us at [email protected]. 

9. How do we secure Users’ data?

SuperAwesome values your trust and strives to maintain adequate security measures for all areas of our business and our services. Because AwesomeAds Marketplace is a service that operates digitally, SuperAwesome is continuously reviewing and improving its security measures to prevent data breaches and security incidents. 

• We have put in place appropriate security measures to prevent Users’ data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 
• We limit access to Users’ data to those employees, agents, contractors and other third parties strictly on a “need to know” basis. They only process Users’ data on our instructions and are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Third party websites, services and apps

Some of the correspondence Authorised Users receive from us may contain links to third party websites, online services or mobile applications that are not affiliated with or operated by us, including those of the Customers who use AwesomeAds Marketplace. While SuperAwesome tries to link only to websites that share our high standards and respect for privacy, we are not responsible and accept no liability for the content, security or privacy practices of those other websites. 

To find out how your personal data may be used by third party websites, refer to the privacy and cookie policies displayed on those websites.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. For example, you may have rights to:

Review/access/delete/restrict the collection of your child’s personal data. Under COPPA, a parent has certain rights over how we handle the personal data of an End User who is their child. This includes the right for a parent to review, access, or delete the personal data that has been collected by us from that End User, and to refuse at any time to permit the collection from that End User of such personal data. 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances, such as where there is no good reason for us to continue to process it. You may also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons of which you will be notified, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data’s accuracy
• where our use of the data is unlawful but you do not want us to erase it
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent as the legal basis upon which to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected]. 

If you are a California resident, please refer to the California residents section below for more information on your legal rights.

No fee usually required

You do not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Do Not Track disclosure Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, AwesomeAds Marketplace does not support and does not act on DNT signal headers that we may receive.

11. Location-specific privacy rules

Depending on where you are resident, specific privacy rules apply:

UK and EEA 

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact the Information Commissioner’s Office (www.ico.gov.uk) which is the regulator responsible for data protection in the United Kingdom, where SuperAwesome Trading Limited is registered (Registration number Z8630714). If you are located in the EEA, you may contact your local data protection authority. You can find contact details here.

United States 

If you are a resident of the United States and believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at [email protected] or by using their online contact form here.

California residents

For the purposes of this section, Personal Information, Sell, Share and Service Provider have the meanings assigned to them under the California Consumer Privacy Act of 2018, (California Civil Code §§ 1798.100 to 1798.199), as amended, and its implementing regulations (CCPA).

SuperAwesome is a Service Provider for its Customers in connection with the provision of the Dashboard. SuperAwesome does not retain, use, or disclose Personal Information for any purpose other than for the specific purpose of performing the services specified in its agreement with Customers, as set out in this Privacy Policy, or as otherwise permitted by the CCPA. The CCPA provides specific rights to individuals who reside in California, including the right to know, delete and opt out of certain data-collection activities.

SuperAwesome, or its Service Providers, collect the following categories of Personal Information:

• IP address, IDFA or UUID (of mobile End Users)
• name, email address or telephone number (of people who contacted SuperAwesome with an inquiry)
• first name, last name, corporate email address and device information (of Authorised Users)

We use and disclose this Personal Information as explained in sections 3. General information about how we process User data and 7. How do we share Users’ data?

We do not Sell or Share this Personal Information (as those terms are defined by the CCPA).

Right to know and access

You may submit a request for the following information:

• the specific pieces of Personal Information we have collected about you
• the categories of Personal Information we collected, sold or disclosed for a business purpose about you
• the categories of sources from which the Personal Information was collected
• the purposes for which the information was collected or sold
• the categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared

Because SuperAwesome is a Service Provider, we may not be able to respond directly to your request. In this case, we will direct you to contact the Customer for additional information. Where possible, we will provide this information to you in a readily usable format that allows transmission to another entity. 

To submit a request, click here to access our online webform or email us at [email protected]. We will confirm your request within 10 days of receipt.

Right to delete

Because SuperAwesome is a Service Provider, we may not be able to respond directly to your request. In this case, we will direct you to contact the applicable third party for additional information. You may submit a request for us to delete any Personal Information we have collected about you. To submit a request, please email us at [email protected] or use this webform.

Verification

Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity considering the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. If we need additional information to verify your identity, we will contact you to request that information.

Right to be free from discrimination

We will not discriminate against you because you have chosen to exercise your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.

Exercising your rights

To submit a request or to otherwise contact us for more information about how to exercise your rights, please follow the instructions above. If you would like to designate an authorised agent to make a request on your behalf, please be sure the agent is able to:

1. demonstrate you have provided written permission for the agent to submit the request on your behalf
2. provide proof of their own identity

If the agent does not satisfy both these requirements, we will deny the request.

California residents’ “Shine the Light” law

We do not share your Personal Information with any unaffiliated third parties for their own marketing purposes.

12. Changes to this Privacy Policy

SuperAwesome has the discretion to update or modify this Privacy Policy at any time. When we do, we will update the “last updated” date on the policy. The most current version of this Privacy Policy is available on the SuperAwesome Privacy Hub and supersedes all previous versions of this Privacy Policy. If the change is material, we will place a notice on the Privacy Hub by revising the link to read substantially as “Updated Privacy Policy” for a reasonable period of time.