1.1 General Conditions: general contract conditions that regulate and govern the performance of the Service.
1.2 Cookies: Cookies are text files (letters and/or numbers) that contain packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. At each subsequent visit, the browser sends Cookies to the website that originated them or to another site. Cookies can be stored only for the time of use of a specific site (i.e. session Cookie), or for a longer period of time independent of the session (i.e. persistent Cookie).
1.3 Adv campaigns: advertising campaigns sold by AdHub Media on Publisher sites.
1.4 Personal Data: any information relating to a natural person, identified or identifiable, directly or indirectly, by reference to the name, an identification number, location data, an online identifier or characteristic elements of his physical, physiological, genetic, psychological, economic, cultural or social identity.
1.5 Information: this document consisting of the information on the processing of Personal Data relating to the Service.
1.6 Profiling: form of Processing of Personal Data, through procedures – wholly or partially – automated, aimed at evaluating or predicting the Publisher’s preferences and interests.
1.7 Publisher: natural person of legal age or legal person who, in the person of his legal representative pro tempore, uses the Service offered by AdHub Media, in order to publish advertisements sold by AdHub Media.
1.8 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.9 Service: organization and management of advertising campaigns on spaces of Publisher Sites via native, video and display ads.
1.10 Site: this site.
1.11 Publisher Site: website owned and/or managed by the Publisher where the Service is provided.
1.12 Owner: AdHub Media S.r.l.
1.13 Processing: any operation or set of operations concerning Personal Data, such as, by way of example, collection, organisation, structuring, conservation, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.
1.14 Users: users of the Publisher Sites.

The Data Controller referred to in this Information is:
a) AdHub Media S.r.l., with registered office in Via Paolo da Cannobio, 9 – 20122 Milan, VAT number IT13542920965 (“AdHub Media”).

Any request from the Publisher relating to the Processing carried out by the Data Controller concerning their Personal Data (including the exercise of the rights referred to in point 8 below must be addressed to AdHub Media by post to its registered office, or by e-mail to the following address info@adhubmedia.com.

The Owner collects and uses the Personal Data of Publishers and Users to achieve the following purposes:
a) allow navigation on the Site, essentially through the use of Cookies.
b) allow Publishers to register on the Site and create a personal account useful for monitoring the Service;
c) provide the Service to Publishers, including the management of the administrative and accounting relationship deriving from the signing of the General Conditions and the sending of communications strictly connected to the performance of the Service of a technical nature (e.g. notification of the progress of the Adv Campaign) and/or of an administrative nature (e.g. updates to this Policy).
➢ The collection of Personal Data for the purposes referred to in letters b) and c) is necessary for the use of the Service by the Publisher. Any refusal prevents the Publisher from using the Service in accordance with the provisions of the General Conditions. These Processings are based on the signing of the General Conditions by the Publisher and on the related pre-contractual measures proposed by AdHub Media.
d) subject to optional consent, carry out statistical analyzes and market research, send information and advertising material, report, and invite to, promotional initiatives of AdHub Media;
➢ The purpose referred to in letter e) is optional and any refusal by the Publisher prevents the latter from taking advantage of marketing activities (including direct and personalized) by AdHub Media. These Processings are based on the free, specific, informed and unequivocal consent of the Publisher, expressed through a declaration or positive action (e.g. flag) on ​​the Site. The revocation of consent can be exercised at any time, following the indications referred to in point 7 letter. a) of this Information.
e) Carry out statistical analyses, market research, improve the presentation of the Service and the use of the Site by the Publishers. Where possible, to achieve this purpose, the Data Controller uses anonymous Personal Data,
➢ The Processing referred to in letter f) is based on the legitimate interest of the Data Controller consisting of the benefit he can obtain in being able to make Publishers an offer that is more similar to the preferences expressed by their Publishers while browsing the Site, taking into account the fact that furthermore It is in the Publishers’ interest to benefit from personalized services. For this reason, the Owner believes that the legitimate interest in developing and implementing the Site and the Service prevails over the Publishers’ right to privacy. The opposition to this Processing (where it concerns Personal and non-anonymous Data) can be exercised at any time by following the instructions referred to in point 7 letter. f) of this Information.

The Data Controller collects Personal Data in the following ways:
a) Personal Data entered into the Site by the Publishers: these are the Personal Data provided, by way of example and without limitation, to browse, register and access the Service offered on the Site;
b) Personal Data expressly communicated by the Publishers in offline mode: are the Personal Data provided, by way of example, to the AdHub Media customer service (in case of contact request) or collected during events and/or initiatives organized by the Owner or communicated upon signing the General Conditions;
c) Personal Data collected automatically by the Site: these are Personal Data collected automatically by the Site through, but not only, Cookies.

Personal Data are processed by the Owner and/or by third parties, selected for reliability and competence, and to whom they may be communicated as necessary or appropriate, provided they are within the European Union. In particular, the Owner informs Publishers that Personal Data may be processed by, and/or communicated to:
a) employees and/or collaborators of the Owner;
b) third party suppliers of services necessary to guarantee the functioning of the Site (for example: companies that provide hosting services);
c) third party suppliers of services necessary for the use of the Service (e.g. payment processors);
d) third party suppliers of IT services and maintenance of the Site;
e) technical third parties who provide analysis services for navigation data on the Site;
f) subject to the optional consent of the Publisher, third parties who provide automatic services for sending newsletters and/or any other type of commercial communication, marketing services, promotion, analysis of habits and consumption choices.

Personal Data is retained by AdHub Media for the period of time strictly necessary to achieve the purposes for which it was collected, as indicated in point 3 above. In particular, unless the right to withdraw consent is exercised pursuant to the following point 7 letter. a) and/or opposition referred to in the following point 7 letter. f):
a) for the use of the Service, the Owner retains the Personal Data for the duration of the General Conditions and for further n. 10 (ten) years from the cessation of use of the Service;
b) for commercial purposes, the Data Controller retains Personal Data for a maximum period of no. 2 (two) years from the collection of the relevant consent by the Publisher.
In any case, the Data Controller is authorized to retain, in whole or in part, the Personal Data for a maximum period of 10 years from collection, limited to the information necessary to fulfill legal obligations and allow the Data Controller to carry out any assessment, exercise and defense of one’s rights in court and/or during tax assessments.
Once these terms have expired, the Data Controller will automatically delete the Personal Data collected, or transform them into anonymous form in an irreversible manner.

Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Information, each Publisher has the right to:
a) with reference to the Processing referred to in point 3 letters d) and e), withdraw consent at any time without prejudice to the lawfulness of the Processing, by sending an email to AdHub Media, exercising the opt-out in the commercial communications, or by deleting the account directly on the Site (see art. 7 of the Regulation);
b) request access to the Personal Data and information on the related Processing and any copy in electronic format, unless the User and/or Publisher specifically requests otherwise (see art. 15 of the Regulation);
c) request the rectification and/or integration of Personal Data, without unjustified delay (see art. 16 of the Regulation);
d) for specific reasons (for example, unlawful processing, revocation of consent, non-existence of the purpose of the Processing), request the deletion of the Personal Data, without unjustified delay (see art. 17 of the Regulation);
e) in the event of the occurrence of specific hypotheses (for example, inaccuracy of the Personal Data, unlawfulness of the Processing, exercise of a right in court), request the limitation of the Processing (art. 18 of the Regulation);
f) with reference to the Processing referred to in point 3 letters d) and e), object at any time to the Processing of Personal Data, by sending an email to AdHub Media (see art. 21 of the Regulation);
g) receive Personal Data in a structured, commonly used and machine-readable format, with the right of portability to another owner without impediments (art. 20 of the Regulation);
h) be informed by AdHub Media without unjustified delay of any violations or unauthorized access by third parties to its systems containing the Personal Data (so-called data breach – see art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country in which he resides, works or where he believes the violation of his rights has occurred (see art. 77 of the Regulation);
For further information regarding the terms and conditions for the exercise of the rights recognized to the User, the latter can consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679, or contact AdHub Media in the ways provided for in point 2 of this Policy.

1. Third party analytical cookies

Google Analytics Cookie
a) Purpose:
they are Cookies provided by Google Inc. to monitor, in anonymous and aggregate form, the statistical analysis of User traffic on the Publisher Site to adapt the Publisher Site to the results emerging from this analysis, in accordance with the interests shown by the Users themselves.

b) Data collected:
data relating to the computer and the User’s visit to the Publisher Site and which, under no circumstances, allow AdHub Media to independently trace the Users’ Personal Data: (i) the domain from which they access the Internet; (ii) the web address from which the User connected to the Site, if available; (iii) the date and time of the connection with the Publisher Site, how long it lasted and which pages were visited; (iv) the computer operating system and browser used by the User; (v) the aggregate demographic detail of the Users who access the Publisher Site.

c) Duration: Session cookies.
For further information on Google Analytics Cookies, the User can consult the following web page: https ://tools.google.com/dlpage/gaoptout.

2. AdHub Media profiling cookies and third-party advertising cookies

AdHub Media profiling cookies:
a) Name: profiler.
b) Purpose: AdHub Media uses profiling Cookies with the aim of improving the commercial experience of Users, by offering content modeled on personal tastes and habits, as well as sending advertising communications relating solely to the products that appear most relevant to the User’s interests.
c) Data collected: data relating to the computer and the User’s visit to the Publisher Site, for the creation of a “browsing profile” of the User, based on the searches carried out by the latter and on the sections of the Publisher Site most consulted.
d) Duration: 30 days.
e) Place of Processing: Italy.

Third-party advertising cookies:
a) Purpose:
Third-party advertising cookies are cookies provided by AdHub Media partners, through links within the Adv Campaign, in order to send information and commercial offers based on interests associated with the User’s online activities. These Cookies do not personally identify Users.

b) Data collected:
data and information on the User’s online orientations and/or preferences such as, for example, the searches carried out, the frequency of page loading or the activity on other third-party sites.

c) Duration:
Session and permanent cookies.

For further information on third-party advertising cookies, the User can consult the following web pages:
i) SSP (Sell Side Platform): Platforms that AdHub Media uses for the monetization of advertising spaces that are aggregated on Publisher Sites
1. Freewheel: http://freewheel.tv/privacy-policy/
2. Improve: https://www.improvedigital.com/platform-privacy-policy/
3. Rubicon: https://rubiconproject.com/privacy-policy/?lang=it
4. Adform. https://site.adform.com/privacy-policy-opt-out/
5. OZ Digital: https://www.ozdigital.com/en/privacy-policy/
6. AOL: https://policies.oath.com/in/en/oath/privacy/index.html
7. Spotx: https://www.spotx.tv/privacy-policy/
8. Google: https://policies.google.com/privacy?hl=it&gl=it
9. Sublime: http://sublimeskinz.com/privacy-en
10. Criteo: https://www.criteo.com/privacy/
11. Onetag: https://onetag.net/privacy/

ii) DMP (Data Management Platform): platforms that AdHub Media uses to create/manage Adv campaigns with audience targeting
1. Neustar: https://www.neustar.biz/privacy/opt-out
2. Navegg: https://www.navegg.com/en/privacy-policy/
3. Omnicom Media Group: http://www.omgitaly.it/pdf/Cookies_Policy_OMG.pdf
4.   Neodata: https://www.neodatagroup.com/it/security-policy/opt-out-opt-in-procedure

The Publisher is required to inform the User of the following.
The User may give their consent to the use of the Cookies described in the previous section 8 through the methods indicated on the Publisher Site (via an information banner that pops up immediately).
The expression of consent can be modified at any time.

This being said, with reference to all Cookies of the Service, the User may change the settings relating to them, according to the methods provided in the control panels of the browser used, such as, for example:

• Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en
• Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
• Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
• Safari: https://support.apple.com/kb/PH19255?locale=it_IT

Furthermore, with specific reference to profiling and advertising Cookies (see point 8.2 of this Policy), in addition to being able to use the tools provided by the browser to activate or deactivate individual Cookies, the Owner informs that if the User does not wish to receive adverts targeted advertisements (i.e. based on the User’s online behavior) displayed by the Owner or by the third parties mentioned above or not known to the Owner, you can disable the display of such targeted advertisements by clicking here www.youronlinechoices.com/it/le-tue-scelte by configuring with the appropriate ON/OFF button the setting for AdHub Media. The procedure indicated above refers to the single browser with which the User is accessing the Publisher Site at a given time. If the User uses multiple browsers to browse the Internet and does not wish to view the targeted advertising messages conveyed by AdHub Media under any circumstances, he or she should repeat the above operation for each individual browser.

When the User deactivates the Owner’s services, the latter places a technical Cookie in the User’s browser so as to be able to memorize his choice and be able to respect it when browsing online. If said technical Cookie is deleted from the browser, the User will have to repeat the deactivation.
The procedure indicated above will only block targeted advertisements conveyed by the Owner and not by any other third parties.