Adexium Ltd ("Adexium", "We", "Us", "Our") provides advertising technology solutions — a self-serve ad network with formats for web traffic (popunder, in-page push, web push) and Telegram traffic (Telegram Mini Apps, Telegram Bot Messages, iMe Messenger), together with related SDKs, APIs and reporting tools (the "Services"). The Services enable publishers and developers of mobile applications, websites and Telegram surfaces to monetize traffic, and advertisers to reach relevant audiences. Publishers, developers and advertisers, as well as ad networks and other platforms connecting them, are collectively named "Clients".
Adexium hosts and processes data on infrastructure located in the European Union. By accessing or using the Services, the Official Website at adexium.io, any SDK, API, ad tag or pixel provided by Adexium, you accept this Privacy Policy in full and without reservation. If you do not agree, you must not use the Services.
Adexium may amend this Privacy Policy at any time at its sole discretion. Amendments take effect upon publication on the Official Website. It is your responsibility to review this Privacy Policy periodically.
1. Information concerning end-users
1.1. Role of the parties. When data relating to an end-user (a person visiting a Client's website, mobile app or Telegram surface) is processed in connection with the Services, Adexium acts as a processor under the GDPR and equivalent laws. Our Clients are the controllers. As a processor, We process such data only on documented instructions from the Client (configured via the campaign creation flow, SDK integration parameters, ad-tag parameters and any agreed data processing addendum). Clients are solely responsible for the lawfulness of such instructions, the lawful basis for processing, end-user consents, transparency notices and the answers to any data-subject requests.
1.2. What information We may collect. We collect only information that our Clients have instructed Us to collect, prior to such collection, and subject to permissions inside Clients' sites, mobile applications, Telegram surfaces and the end-user's device.
For example, Our code embedded on Clients' sites and applications does not collect precise location data unless the end-user has affirmatively allowed/enabled the Client to collect it. We avoid collecting information that identifies a person directly, such as name, postal address or email. When you interact with any site, app or Telegram surface of our Client that uses the Services, We may automatically collect or receive:
- information about your device — device type and model, network provider, browser type, operating system, language;
- log information — the app/site/surface visited, session start/stop time, time zone, referrer URL, network connection type and cookie information;
- information about Clients' sites and applications — ad placement data, keywords, version;
- mobile advertising identifiers — Apple IDFA or Google Advertising ID — only where the device permits and provided by the Client;
- information provided by your device — IP address, network connection type and approximate geo-location (country, region, city), user-agent string;
- messages and correspondence sent to Us (email, Telegram support, feedback forms);
- other non-identifying information shared with Us by Clients and third parties — e.g. content viewed, language preference or interest categories — to help make ads more relevant.
1.3. How We use the collected information. We use such information solely to perform the Services on behalf of Clients and for purposes described in this Privacy Policy. You are not required by law to provide Us with personal information. Specifically:
- to provide the Services;
- to enable and optimize the Services' tools and features;
- to study and analyze functionality of the Services and aggregated end-user activity;
- to provide support to Clients;
- to measure Services' activity for pricing and billing purposes;
- to detect and prevent fraud, invalid traffic, bot traffic, malware and abuse;
- to maintain and continue developing the Services.
We may create an aggregated interest profile to help our Clients improve user experience and serve more relevant ads. We will not combine non-personally identifiable information with directly identifying information without express consent.
1.4. How We may share information. We may share information collected:
- with the relevant Client — to serve contextual and/or targeted ads, for reporting and campaign performance analysis, and to understand engagement with ads;
- with third-party service providers — anti-fraud, bot detection, viewability, geo-location, ad security and verification, hosting and CDN — strictly to operate the Services;
- with Our corporate affiliates for the purpose of providing the Services;
- where required by applicable law, court order, regulator request or law-enforcement demand, or to protect Adexium's rights, property or safety;
- in any other circumstances with express consent.
1.5. End-user choice. You can opt out from personalized advertising:
- Web: https://rtb.pltfrm.cloud/users/sync/opt-out
- iOS in-app: https://support.apple.com/en-us/HT202074
- Android in-app: https://support.google.com/ads/answer/2662922?hl=en
1.6. Data-subject rights. Since Adexium acts as a processor for end-user data, requests to exercise data-subject rights (access, rectification, erasure, restriction, portability, objection) should be submitted to the relevant Client (the controller). Where a request is sent directly to Adexium, We will, where reasonably possible, forward it to the relevant Client and assist that Client in fulfilling the request, without assuming controller obligations.
1.7. Client warranties and obligations. Clients warrant and undertake that they will:
- comply with all applicable laws and regulations, including GDPR, ePrivacy, CCPA/CPRA and equivalent;
- provide all required notices to end-users about the collection and use of personal information for advertising purposes;
- obtain all required end-user consents (including for cookies, similar technologies, personalized advertising and any cross-context behavioral tracking) and maintain a valid consent-management mechanism;
- maintain a lawful basis for every processing activity instructed to Adexium;
- not direct or knowingly enable the Services to be used in respect of children under 16, or to collect Prohibited Data;
- not transmit any "special category" personal data (health, biometric, racial, religious, sexual-orientation, etc.) to Adexium;
- not transmit any directly identifying data (name, email, phone, government ID) to Adexium beyond what is strictly required to operate billing and account features under Section 2.
Clients indemnify Adexium against any claim arising from a breach of these warranties (see Terms & Conditions, clause 9.4).
1.8. Children. We do not permit the Services to be used to collect information from sites and apps directed to children aged 16 or under for the purposes of creating interest-based profiles or serving ads based on inferred interests. We may collect information from such sites only for other purposes (e.g. contextual ads).
1.9. Retention. We retain end-user information for as long as the relevant Client uses the Services and for up to 365 days thereafter, for purposes of reporting, billing, fraud prevention and dispute resolution, or until the Client (controller) instructs deletion in writing, or until We are legally required to retain it.
2. Information concerning Clients (advertisers / publishers)
2.1. Role of the parties. When We process personal data of our Clients themselves (the natural persons who register on the Official Website, interact with the dashboard, sign up for billing or contact Us), Adexium acts as a controller under the GDPR and equivalent laws.
2.2. What information We may collect.
- contact information: name, company name, physical address (where required), phone number, email, Telegram handle;
- financial information: bank account numbers and/or card numbers, crypto wallet addresses used for top-ups and payouts, and related transaction history;
- detailed personal information where required by law (KYC, AML, sanctions screening): date of birth, national ID number, country of company registration, beneficial-owner information;
- account activity, support correspondence and any personal information you provide when contacting Us.
2.3. Lawful basis (GDPR). We process this data on the basis of:
- performance of the contract between you and Adexium (Terms & Conditions);
- our legitimate interest in operating, securing and improving the Services, preventing fraud and abuse, and pursuing payments due;
- compliance with legal obligations (tax, accounting, AML, sanctions, court orders);
- your consent, where consent is the legally required basis.
2.4. How We use the collected information.
- provide the Services, related products and Client support;
- process transactions and send notices about transactions;
- collect fees and pursue any sums owed;
- conduct KYC, AML, sanctions and fraud-prevention checks;
- resolve disputes and troubleshoot problems;
- prevent potentially prohibited or illegal activities;
- customize, measure and improve the Official Website, content, products and Services;
- contact you by email or in-platform messaging.
2.5. How We may share information.
- with service providers under contract — fraud prevention, billing, KYC/AML, accounting, marketing, technology services;
- with payment processors and financial institutions to process transactions;
- with trusted advertisers/publishers for account verification or to enable specific Services features;
- within Our corporate affiliates to provide, understand or improve the Services;
- with regulators, tax authorities and law-enforcement bodies where legally required;
- with acquirers, investors or successors in connection with corporate transactions (see clause 3.6).
2.6. Retention. We retain Client information for as long as you are our Client and for at least 365 days thereafter, or longer where required by law (tax, accounting, AML — typically up to 7 years), for internal reporting, invoicing, dispute resolution and fraud prevention, or until We delete it pursuant to your written request and confirm such deletion is lawfully possible.
3. General provisions
3.1. Transfer of information. Our infrastructure is hosted in the European Union. If you access the Services from outside the EU, the information you provide will be transferred to and processed in the EU. Where We transfer personal data to a country outside the EU/EEA that has not been recognized as offering an adequate level of protection, We rely on appropriate safeguards under the GDPR (such as Standard Contractual Clauses).
3.2. Cookies and similar technologies. When you visit the Official Website or use the Services We may place small data files on your computer or device — cookies, beacons, pixel tags, local storage entries and similar identifiers (collectively "Cookies"). We use these to recognize you as a Client or Client's end-user; customize Services, content and advertising; measure promotional effectiveness; ensure account security; mitigate risk and prevent fraud; and promote trust and safety. You are free to decline Cookies if your browser permits, unless they are strictly necessary to prevent fraud or ensure security. Declining Cookies may interfere with use of the Services.
3.3. Information security. We implement physical, technical and administrative security measures designed to safeguard personal information. However, no method of transmission over the Internet or electronic storage is fully secure. To the maximum extent permitted by law, Adexium cannot guarantee absolute security and does not accept liability for unauthorized access, disclosure, loss or alteration of personal information caused by events outside Adexium's reasonable control (including breaches of third-party services, force majeure, sophisticated cyberattacks, or compromise of the user's own credentials or devices). You are responsible for keeping your account credentials secure.
3.4. Accessing your personal information. At any time you may contact Us at support@adexium.io and request to access, correct, receive a copy of, or request deletion of the personal information We keep about you as a Client. We may ask you to provide credentials to verify your identity. We may refuse or postpone the request where the data is in active use for the Services, or where another legitimate purpose or legal obligation requires retention.
3.5. Your data-subject rights under the GDPR (Client data). As an EU resident whose data We process as controller, you may:
- withdraw consent at any time (without affecting the lawfulness of processing performed before withdrawal);
- request access, correction, deletion or restriction of your personal information;
- ask to receive your personal information under the right to data portability where applicable;
- object to processing based on legitimate interests, including direct marketing;
- not be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you;
- lodge a complaint with a data-protection supervisory authority in the EU.
Adexium may decline or limit the exercise of these rights to the extent permitted by law (for example where contractual, legal or fraud-prevention obligations require continued processing).
3.6. Changes in corporate structure. We may share information you provided to Us if We are involved in a merger, acquisition, restructuring, financing or sale of all or a portion of Our assets, as part of such transaction or related due diligence. Continued processing by the successor will be governed by a privacy policy substantially equivalent to this one. Notice will be given via a prominent notice on the Official Website where required by law.
3.7. Changes to this Privacy Policy. We may update this Privacy Policy from time to time. Updates take effect upon publication on the Official Website. Continuing to use the Services after publication constitutes acceptance. Where legal requirements demand earlier or different timing, the new policy will take effect as required by law.
3.8. No third-party beneficiaries. This Privacy Policy does not create any third-party beneficiary rights enforceable against Adexium.
3.9. Limitation of liability. To the maximum extent permitted by applicable law, Adexium's total aggregate liability arising out of or relating to this Privacy Policy is subject to the liability cap and exclusions set out in the Terms & Conditions (clause 8), including the cap at twofold the latest payment from the relevant Client. End-users who are not Clients have no contractual relationship with Adexium under this Privacy Policy.
3.10. Contact. For any requests concerning your personal information or queries regarding this Privacy Policy, contact Us at support@adexium.io.