Overview

Monet Engine Inc (AdaptMX) provides advertising technology products and services including its server advertising exchange, the Monet Engine APIs, and the Monet Engine websites (the “Monet Engine Services” or “Services”). Our products and services enable publishers of websites and mobile applications (“apps”) to display advertisements on their sites and apps, from advertisers that are interested in promoting their products or services. This Privacy Policy explains how Monet Engine collects and uses information about end users of apps and sites that use the Monet Engine Services, publisher and advertiser customers that use the Monet Engine Services (collectively, “Monet Engine Customers”), and visitors to Monet Engine’s websites.

Section 1 describes how Monet Engine gathers and applies information from end users in providing the Monet Engine Services; Section 2 describes how Monet Engine gathers and applies information about Monet Engine Customers and the information Monet Engine collects when a person visits and uses the Monet Engine website; and Section 3 describes privacy policies that apply to both the information we collect from end users through the Monet Engine Services and the information we collect from Monet Engine Customers and visitors of our website.

Section 1: End User Information

The Information We Collect

When you interact with a website or app that uses the Monet Engine Services, we may collect information about your device and the ads you view or click. The Monet Engine Services are designed to avoid collecting information that identifies you personally, such as your name, address, or email address. The information we collect includes, but is not limited to:

• Information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser (e.g. Chrome, Safari), applications and websites using the Monet Engine Services and the version of such applications, and advertising identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA) or Android Advertising ID.

• Log information, including the app or website visited, session start/stop time, time zone, and network connection type (e.g., WiFi, cellular), and cookie information.

• Information that Monet Engine Customers and other third parties have collected and shared with Monet Engine, such as information about activity in their services. This may include the content you view, the language you prefer, or other non-personally identifying demographic or interest information, to help make the ads served to you more relevant.

• Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or purchased the product or service advertised.

How We Use the Information We Collect

We use the information we collect to provide and improve Monet Engine Services, including for the following purposes:

• Ad Reporting and Conversions: Reporting to advertisers information about when and how users have been exposed to their ads, clicked on their ads, or visited their website, and reporting to publishers information about when and how ads were shown on their properties and were clicked on.

• Serving ads: Allowing publishers to offer advertising inventory in their mobile apps and websites, and advertisers to bid on and fill that inventory.

• Geo-Targeting: Where permitted by the user’s device, allowing Monet Engine and Monet Engine Customers to serve ads based on a user’s location.

• Frequency Capping: Preventing users from seeing the same ad too many times.

• Providing and Improving Our Services: Auditing, researching, and analyzing data in order to maintain, protect, and improve our Services and develop new services, and to ensure that our technologies function properly.

• Fraud Detection and Prevention: Identifying invalid clicks (or ad queries) and protecting Monet Engine and Monet Engine Customers from fraudulent behavior.

How We Share the Information We Collect

We share the information we collect to provide and improve Monet Engine Services, as follows:

• We share aggregate or non-personally identifiable information about the use of our Services with Monet Engine Customers. For example, we provide advertisers reports showing how many users viewed or clicked on their ads. We also provide publishers reports about the types of ads served to their websites or apps.

• We share with data partners who help Monet Engine Customers to improve the performance of their bids or inventory on our advertising exchange.

• We share with advertiser customers information so that they can decide whether to bid on ad inventory or serve an advertisement and choose the best ad for that device. Monet Engine Customers are obligated to use the information they receive in compliance with applicable laws and regulations.

• We share information within our corporate family to provide, understand, or improve their or our services.

• We share information as described in Section 3 of this privacy policy.

• We share with partners who help with anti-fraud, quality, and security efforts to ensure the safety, security, privacy, and accuracy of the Monet Engine ecosystem.

Choices

Your iOS mobile device may provide a “Limit Ad Tracking” setting. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using this setting on a device, Monet Engine will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests. Your mobile web browser may also provide a “Do Not Track” browser setting. When you have enabled this setting in your browser, Monet Engine will not use mobile web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests. Monet Engine requires its advertising customers to honor opt-out preferences expressed using these controls.

Please visit adaptmx.com/do-not-track for more opt out options.

Children

Monet Engine does not permit the Monet Engine Service to be used to collect information from apps directed to children for purposes of creating interest-based profiles or serving ads based on users’ inferred interests. Monet Engine may collect information from apps directed to children for other purposes, such as serving advertisements based on contextual information, like the the content or type of the application (for example, serving an ad for a video game to a gaming app).

Privacy Practices of Monet Engine Customers

Monet Engine requires Monet Engine Customers to comply with all applicable laws and regulations and to provide end users with notice of the collection of data for advertising purposes as outlined in this Privacy Policy. We encourage all users to review the privacy policies of sites and apps they visit for information about those sites’ and apps’ data collection and use practices.

Section 2: Data Collected from Monet Engine Customers and on Monet Engine’s Websites

Personal Information

To become a Monet Engine Customer, you may be asked to provide certain personal information, including your name, email address, physical address, phone number, and company name. You also may be asked to provide personal information in certain fields on this website. Registration information is used to provide the Monet Engine Services and to send promotional information about the Monet Engine Services. To opt out of receiving promotional information, please follow the unsubscribe instructions in any of our promotional emails or contact us at privacy@adaptmx.com. If you are a registered user of our Services, we provide you with account tools to access, correct, or modify personal information you have provided to us in association with your account. If you wish to delete your account, you may do so by contacting privacy@adaptmx.com.

Information Sharing and Disclosure

We may disclose information about Monet Engine Customers when necessary to provide the Monet Engine Services to them, such as for account inquiries or verification, or to enable participation in certain features of our mobile advertising exchange. We may also share information within our corporate family to provide, understand, or improve their or our services, and as described in Section 3 of this privacy policy.

Web Log Information

When you visit our websites, our servers automatically record certain information in our log files. This web log information includes your IP address, browser type, operating system, the referring web page, pages visited, and cookie information. Like many websites, we use web log information, along with cookies, pixels, and similar technologies, to operate our websites, better understand how they are used, resolve technical problems, and enhance your experience on our sites.

Cookies are small files that websites place on your computer as you browse the web. A pixel is a small amount of code on a web page and is often used in connection with cookies. Most web browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some sites may not function properly if you disable cookies.

Section 3: General Information

Information Provided by Third Parties

We may receive information about you from third parties, including Monet Engine Customers, data partners, and our corporate family. This information may include, for example, browser cookie IDs, mobile device IDs, demographic or interest data, and content viewed or actions taken on a website or app.

Information Collected by Others

Please be advised that we do not control and are not responsible for the privacy practices of any third party, including, but not limited to, Monet Engine Customers and any website or service that links to or from our website or the Monet Engine Services. We require Monet Engine Customers to maintain a privacy policy that fully and accurately discloses their data collection practices, but we cannot control the actions of Monet Engine Customers, so please be sure to review the privacy policies of any websites and applications that you may use. The Monet site may contain links to other sites. Monet Engine is not responsible for the privacy practices or content of these other sites. When you leave our site or view a portion of a third party’s site through our site, we encourage you to read the privacy policies of each such site. This Privacy Policy applies solely to information collected by Monet Engine.

Information Sharing and Disclosure

We engage service providers to perform functions and provide services to us and our Monet Engine Customers in the United States and abroad. We may share the information we collect with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your information only on our behalf and pursuant to our instructions.

Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect the rights or property of Monet Engine, Monet Engine Customers, users of our website, or end users.

We may also share information when we have your consent to do so.

Confidentiality and Security

Monet Engine has implemented reasonable security measures in order to protect both personal and non-personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction.

Consent to Data Processing and Transfer

When you use or interact with any of the Monet Engine Services, including by using websites or applications that have integrated the Monet Engine Services, you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. This includes any information you choose to provide that is deemed sensitive under applicable law.

Irrespective of which country you live in, you authorize us to use your information in, and as a result to transfer it to and store it in, the United States and any other country where we, our service providers, and our Monet Engine Customers operate. Privacy and data protection laws in some of these countries may vary from the laws in the country where you live.

Duration of Processing

The amount of time our cookies remains on your browser is 1 year and it will be renewed every time you visit a publisher’s digital property.

European Data Protection Regulations

Any international transfers of your data is ensured by us to be compliant with the laws of the European General Data Protection Regulation (GDPR). Appropriate legal protections are in place when data is transferred outside of the European Economic Area (EEA) to the UK, Switzerland, or any other country. Technical measures (such as encryption of data) and legal mechanism (such as the Standard Contractual Clauses) are in place for the protection of data transfers. 

California Residents

The California Consumer Privacy Act (CCPA) requires to disclose to California residents below:

• Specific pieces of personal information collected
• The categories of personal information collected
• The purposes for which we use personal information
• The categories of third parties with whom we share personal information with
• The categories of sources from which we collect personal information
• The categories of information that we “sell” or discloses to third parties
• Information as to how you can access, delete, or opt-out of the sale of your personal information.

This information will be provided for the 12 month period preceding your request. Please do not hesitate to contact us at privacy@adaptmx.com.

Data Privacy Framework

This Data Privacy Framework notice sets out the privacy principles we follow with respect to transfers of personal information from the European Union (“EU”), UK and Switzerland to the United States, including personal information we receive from individuals who visit our web and mobile sites, who interact with our Digital Media Properties (as defined in our Advertising Technology Privacy Policy ), and who otherwise communicate or interact with us.

Changes in Corporate Structure

In the event that Monet Engine is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity.

Contact Us

If you have questions about this policy, or inquiries or requests regarding your information, please contact us at privacy@adaptmx.com.