Last Updated 6/3/2016
Adomni, Inc. (hereinafter referred to as “Adomni”, “we”, “us” or “our”) operates a platform and community marketplace that helps people form relationships directly with one another to buy and sell units of time that display advertising content on billboards around the world, whether through our website or our mobile applications (“Platform”).
“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.
“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.
“Data Controller” means Adomni, the company responsible for the use and processing of Personal Information.
“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and Adomni.
“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
WHAT TYPES OF INFORMATION DOES ADOMNI GATHER ABOUT ITS USERS?
A. Information that you give us
We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:
- fill in any form on the Platform, such as when you register or update the details of your user account;
- access or use the Platform, such as to search for or post Billboards, make or accept Reservations, pay for Reservations, book or pay for any associated services that may be available, or communicate with other users;
- communicate with Adomni; and
- share information with another User.
B. Information we get from your use of our Platform
We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Adomni or logged in to your Adomni Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.
- Cookies and other Tracking Technologies
While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Adomni services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.
HOW ADOMNI USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
We use, store and process information about you for the following general purposes:
- to enable you to access and use the Platform;
- to enable you to communicate with other Users, including but not limited to by sending them messages or other information during the Reservation placement or Content Approval process;
- to operate, protect, improve and optimize the Platform, Adomni’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;
- to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Adomni, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account Information” section) when you login to your Adomni Account;
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.
WHEN ADOMNI DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM
IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries.
We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
Your Personal Information may be disclosed as follows:
A. Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.
B. Your public Billboard Details page will always include some minimum information such as the city where the Billboard is located, your billboard description and your calendar availability. Parts of your public Billboard Details page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display the Billboard’s approximate geographic location on a map, such that a user can see the general area of the Billboard.
C. The Platform allows your public Billboard Details pages to be included in search engines, in which case your Billboard Details pages will be indexed by search engines and may be published as search results. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.
D. When you submit a reservation to book one or more spots on a Billboard, your full name and your company name (if applicable) and other Personal Information will become visible to the Billboard Owner. We will not share your phone number and your billing and payout information will never be shared with another user.
E. We may distribute parts of the Platform (including your Billboard Details Page) for display on sites operated by Adomni’s business partners and affiliates, using technologies such as HTML widgets. If and when your Billboard Details are displayed on a partner’s site, information from your public profile page may also be displayed.
H. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:
- providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
- we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Adomni’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).
- In instances where Adomni complies with legal requests for user data without notice to the user for the reasons described above, Adomni will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
I. We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
STATE PRIVACY LAWS
For California & Vermont residents: Adomni will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by your state’s law.
BUSINESS TRANSFERS BY ADOMNI
HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR Adomni ACCOUNT
You may review, update, correct or delete the Personal Information in your Adomni Account. If you would like to correct your information, you can do so by logging in to your Adomni Account. To cancel your Adomni Account entirely, please email us at email@example.com. Please also note that any information posted by you may continue to be publicly available on the Platform in association with your first name, even after your Adomni Account is cancelled.
SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
FOR USERS RESIDING IN THE EU: YOUR RIGHT TO SEE AND CHALLENGE INFORMATION PROVIDED TO US BY THIRD PARTIES
You are entitled to see and challenge any information that Third Parties may provide to us as part of our fraud detection, prevention and risk assessment efforts in circumstances where all of the following factors apply: (i) if we use Third Parties to carry out automated checks or risk assessments, and (ii) if we make a decision which has legal consequences for you or which significantly affects you, and (iii) if such decision is based solely on such automated checks or risk assessments. In order to request this, please address your request directly to Adomni, Privacy Office, 7120 Rafael Ridge Way, Las Vegas, Nevada 89119. Please state clearly in your request that you wish to see and/or challenge the information that Third Parties may have provided to Adomni as part of our fraud detection, prevention and risk assessment efforts. We may request proof of identification to verify your request.
Adomni uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.
Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.
A. Adomni cookies and Third Party cookies
- We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes.
- There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.
- Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.
B. Other technologies
The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
C. Uses for Adomni cookies
- to enable, facilitate and streamline the functioning of the Platform across different webpages, devices and browser sessions.
- to simplify your access to and use of the Platform and make it more seamless.
- to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
- to show you content (which may include advertisements) that is more relevant to you.
- for fraud detection and prevention.
D. Uses for Third-Party cookies
In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the Adomni mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.
E. Disabling Cookies
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel