PURPOSE

This Privacy Policy is provided to help you understand how Accordmax Digital processes (i) end user data on behalf of our clients, and (ii) your data when you visit Accordmax Digital’s corporate family of websites, including Accordmax Digital.com (the “Websites”). It does not state the use practices or policies of our clients, of the websites or apps on which ads are shown, or of other parties.

'You' shall mean You, the User of the Website/ Application/ Service and ‘Yourself’ interpreted accordingly. 'Accordmax Digital’ / 'We' / 'Us' means Accordmax Digital and 'Our' interpreted accordingly. 'Users' means the Users of the Website/ application/ Service collectively and/or individually as the context allows.

ELIGIBILITY

At Accordmax Digital, we are committed to respect the privacy choices of our clients and website visitors. We cares about how end user data is collected, used, and shared. We are a “data processor” that collects and analyses end user data at the specific request of our clients, the “data controllers”.

By accessing the Website or using our Services, you become subject to this Policy. Your acceptance of the terms of this Policy, in their entirety, shall be effective to your employees, if any.

THE INFORMATION WE COLLECT

Platform and Data Pledge Our clients use Accordmax Digital services to measure and manage their online relationships. Clients use Accordmax Digital to assess the effectiveness of their partner relationships and act on those results.

Pursuant to our Data Pledge, our clients determine the data that they provide to and collect through Accordmax Digital. Clients’ use, collection, exportation, or any other use of end user data is governed by their own privacy policies and applicable laws, rules, or regulations.

What Information Does WE Collect from Clients?

At the direction of our clients, who act as data controllers, we collect the following types of information from end users to help clients measure and manage their marketing partner relationships:

Ad Identifiers (unique character strings associated with user devices that help monitor and measure user interactions with advertisements and apps, such as Apple’s IDFA and Google Ad ID; Ad Identifiers may be reset by the user) Cookies

Pixel tags

IP address Imprecise geographic location data derived from IP address and/or Wi-Fi networks Our clients may also choose to share certain account information for both clients and their partners on the Platform. This may include corporate and employee information necessary to maintain the services and up-to-date contact information, including: name, mailing and/or billing address, email address, company name, website URL, user name, password, and phone number. Clients using our service to manage payouts to their partners may also choose to share certain banking information as necessary to carry out the services.

Clients can also choose to view and measure information provided by other third-party sources in the Platform. Those sources may include advertisers, publishers, marketing partners, and other advertising networks and analytics partners. Marketing partners may sign up with advertisers through the Accordmax Digital Platform or through their own customer website. Marketing partner information provided to our advertiser clients may be used by us for fraud prevention purposes and to fulfill contractual requirements with our advertisers.

Clients own the data that they provide to and collect through the Accordmax Digital Platform. When clients remove or export their data from the Accordmax Digital Platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations. Accordmax Digital serves as a data processor, acting at the direction of our data controller clients. Specific fields that likely contain personal data, such as IP address or device ID, may be obfuscated or blanked, respectively, by the Accordmax Digital client

What Information Does WE Collect on the Websites from End Users?

When you visit the Websites, Accordmax Digital collects information about your device and use of the Websites to understand how to improve its Websites. Accordmax Digital also collects any information you voluntarily provide when you visit the Websites to learn more about Accordmax Digital and its products, sign up for our services, or apply for employment at Accordmax Digital. The type of information collected will depend on your request and interaction with the Websites.

Categories of information may include specific times of day you accessed the Websites, the IP address of the device you used to access the Websites, the pages on the Websites that you viewed, the pages you visited before navigating to the Website(s), and information about the device you use to access the Websites, including hardware model, operating system and version, and browser.

We use the information collected on the Websites for various purposes, including: Ensuring websites remain relevant to end user needs and are easy to use by providing analytics and other data regarding use of our Websites. Sending marketing and promotional communications in compliance with applicable laws. Enhancing, improving, or modifying its Websites and services, enhancing security, or combating spam or malware or other security risks. Providing confirmations, invoices, technical notices, updates, security alerts, and other support and administrative messages. HOW WE MAY USE THE USER INFORMATION

How Do Clients Use Accordmax Digital To Collect Information from Users? Clients may use Accordmax Digital for pixel or server postback tracking to collect certain marketing information about end users. Pixel tracking (also called “cookie-based tracking” or “client-side tracking”) methods store an Accordmax Digital session identifier in a user’s browser cookie on click. In postback tracking (also called “server-side tracking”), Accordmax Digital directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to Accordmax Digital for validation.

We also support server-to-server measurement for some clients. With any of the mentioned methods, when an end user clicks on an advertisement and goes to a specific web page or mobile app action that a client chooses to measure, we collect information from the user’s device, including but not limited to IP address and ad identifiers.

How May Clients Use Accordmax Digital To Process Information from End Users?

Measuring performance of ad campaigns, including creation of customized performance reports Measuring performance of various marketing partners selected by the client Serving ads through our services using data that does not personally identify users Managing relationships with marketing partners, including payouts on measured conversions and establishing automated workflows to establishing advertising offers.

Publications

If you no longer wish to receive our publications (e.g. newsletters, blog digests), you may opt out using the unsubscribe link located at the bottom of each communication. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. We will respond to your opt out request to access within a reasonable timeframe.

END USER CHOICE, OPT OUTS, AND DISABLING COOKIES AND ADVERTISING IDENTIFIERS Cookies and Web Becons

You should be aware that information and data may be automatically collected through the Use of Cookies or web beacons or similar tracking technologies. "Cookies" are text files placed in your computer browser that store basic information that a Website can use to recognise repeat site visits and as an example, recall Your name if this has been previously supplied. We may use this to understand Your service and internet usage, observe behaviour and compile aggregate data in order to improve or customize our products, services offerings or the Website, target the advertising and assess general effectiveness of such advertising. Cookies do not attach to Your system and damage Your files. If You do not want information collected through the Use of Cookies, there is a simple procedure in most browsers that allows You to deny or accept the Cookie feature. Note, however, that "personalised" services may be affected if the cookie option is disabled.

For example, We may use Cookies to personalize Your experience at our Services (e.g., to recognize You by name when You return to Our Website), save your password in password-protected areas. We also may use Cookies or other tracking technologies to help Us offer You products, offerings or services that may be of interest to You when You visit this Website. We or a third party platform with whom We work may place or recognize a unique cookie on your browser to enable You to receive customized offers, services on this Website. These Cookies contain no information intended to identify You personally. The Cookies may be associated with de-identified demographic or other data linked to or derived from data You voluntarily have submitted to Us (e.g., your email address) that we may share with a service provider solely in hashed, non-human readable form.

We and our Partners may also use "web beacons" or clear GIFs, or similar technologies, which are small pieces of code placed on Our Website or in an email, to monitor the behaviour and collect data about the visitors viewing Our Website or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that Website. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).

End users can disable cookies in most internet browsers. An overview of the process is available here. Disabling cookies will not, however, stop receipt of all advertisements. If an end user would like to opt out of a particular ad network, publisher, or advertiser’s ads, they will need to contact those companies directly to inquire whether they have an opt-out option. End users can also disable collection of Ad Identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the Ad Identifier altogether using their smartphone’s privacy settings. Accordmax Digital collect data on behalf of its business clients, and is not an end user facing company.

Local Shared Objects (Flash Cookies) and Local Storage (HTML5) Opt Out Third parties with whom we partner may use local shared objects (flash cookies), and we and our third parties use local storage (HTML5) to provide certain features on our Websites, to display advertising based on your web browsing activity, and to store content information and preferences. Various browsers may offer their own management tools for removing HTML 5. To manage Flash cookies, please click here.

SECURITY AND DATA STORING

How Does We Adhere to GDPR Principles?

Accordmax Digital serves as a data processor under GDPR, and adheres to the principles and rules of GDPR. Specifically, we implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with sub-processors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners. (In addition to GDPR, we respect and adhere to similar data privacy laws in other jurisdictions as well)

To end users who access the Websites: we retain your information for as long as your account is active or as needed to provide you our services. In most cases, reliance on Accordmax Digital’s existing data retention rules will satisfy the end user request within a reasonable period of time. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law.

Data Retention, Use, Access, Corrections, and Removal

Accordmax Digital retains your information for as long as your account is active or as needed to provide you Accordmax Digital services. Accordmax Digital applies data retention rules to abide by data minimization principles. In most cases, reliance on Accordmax Digital’s existing data retention rules will satisfy the end user request within a reasonable period of time. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law and helpful for the service to function properly.

Under GDPR, you have the right as a data controller to:

Request information about the processing of your data, as well as the receipt of a copy of your personal data. You can request information on the purposes of the processing, the categories of personal data being processed, the recipients of the data (if they are passed on), the duration of the storage or the criteria for determining the duration. Correct your data. Should your personal data be incomplete, you have the right to complete the data, taking into account the processing purposes. Delete or block your data. Reasons for the existence of a cancellation/blocking right can be, among others, the revocation of the consent on which the processing is based, the data subject objects to the processing, the personal data were processed unlawfully. Restrict the processing. Object to the processing of your data. Revoke your consent to the processing of your data in the future. Complain to the competent supervisory authority about inadmissible data processing. Legal Basis Your data will be processed on the following legal bases:

Your consent to data controllers in accordance with Art. 6 (1)(a) GDPR; For the performance of a contract with you in accordance with Art. 6 (1)(b) GDPR; For the fulfilment of statutory obligations in accordance with Art. 6 (1)(c) GDPR; or From a legitimate interest in accordance with Art. 6 (1)(f) GDPR (and, to the extent we base the processing of your personal data on legitimate interests, such data will only be sued to improve or carry our services, protect against misuse or fraud, and maintain statistical integrity with business partners and customers).

Data Transfers

In the process of providing services to you, we may transfer information that we collect to affiliated entities, or to other third parties across borders from your country or jurisdiction to other countries or jurisdictions around the world. By using the Websites or signing up for an account with us, you consent to the transfer of your information to the respective/related country.

Security

Accordmax Digital uses commercially reasonable efforts, including a variety of security technologies and procedures, to help protect client and end user data from unauthorized access, use, or disclosure, both during transmission and once it is received.

INFORMATION SHARING AND DISCLOSURES

Except as described in this Privacy Policy, we will not share personally identifiable information collected on the Websites or in our Platform with other people or non-affiliated companies unless we have your consent, or under the following circumstances:

With third party service providers who work for us and need access to your information to do their work on our behalf, such as providing customer support features, processing payments, and storing data (e.g. Amazon Web Services). All such third-party vendors have agreed to protect the confidentiality of information provided by us.

To protect the rights and property of Accordmax Digital, our agents, customers, users, and others, including to enforce our agreements, policies, and terms of use. If required to do so by law, such as to comply with a subpoena or court order, or in the good-faith belief that such action is reasonably necessary to protect our rights, protect your safety or the safety of others, prevent fraudulent, malicious, or unlawful activity, investigate fraud, or respond to a government request. As part of any merger, acquisition, debt financing, or sale of company assets or other event in which information could be transferred to third parties as one of the business assets of the company. We may also share aggregated or anonymized information in a form that does not directly identify you or any end users with any third parties.

Our Website includes links to other websites whose privacy practices may differ from those of Accordmax Digital. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

LINKED SERVICES

Our Website may contain links to or integrations with other services such as Facebook, Twitter, LinkedIn, and other media services and platforms whose information practices may be different than ours. Visitors should consult these other services' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by and operated in accordance with the laws of India. If any of the parties wish to seek legal recourse, they may do so by using the courts of law in New Delhi.

ACCEPTANCE

By visiting our website, signing up or logging into the website, uploading information on our website; you acknowledge and unconditionally accept the policy. If you do not agree with this Policy, do not use our website and services or provide here any of your personal data.

UPDATES

Accordmax Digital may find it necessary to update this Privacy Policy from time to time. Please check this Privacy Policy regularly, as any changes will be posted on this site.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, or have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at business@accordmax.com

Last Revised: Jul 07, 2023