For AnyDigital Premium Marketplace Service
1.1 AnyMind Group Pte. Ltd. (“AnyMind”, “us”, “we”, or “our”) operates an advertising marketplace (known as the AnyDigital Premium Marketplace) that provides advertising solutions to advertisers and publishers from the Asia-Pacific region (“APAC”). These advertising solutions range from the static display of content through banners on our publishers’ websites to video advertisements displayed on these websites (“Ad and Video Network Service”).
1.2 Through our AnyDigital Premium Marketplace, website publishers are able to monetize their website traffic effectively by tapping into the combined demand from AnyMind and third-party sources.
1.3 AnyMind believes in protecting the online privacy of our users and clients alike. We have formulated this Privacy Policy to outline our policies regarding the collection, use, and disclosure of non-personally identifiable and personally identifiable information (also referred to as “Personal Data”) in respect of our AnyDigital Premium Marketplace.
1.4 Publishers within the AnyDigital Premium Marketplace are also required to abide by the AnyDigital Platform Terms of Service.
1.5 Your continued use of our AnyDigital Premium Marketplace and/or other services constitutes your acceptance of the terms of this Privacy Policy.
1.6 If you do not wish to accept the terms of this Privacy Policy, you shall discontinue the use of our Ad and Network Service and/or any other services provided by AnyMind. You may also refer to the opting-out options that have been set out below.
2.1 We may collect the information listed below about your activities when you visit our publishers’ websites and use our Ad and Video Network Service (“Activities Information”).
2.2 ACTIVITIES INFORMATION
2.2.1 Activities Information means the information that enables us to:
(a) Make online advertisements relevant to you;
(b) Monitor, assess and track the success of advertising campaigns;
(c) Provide reports and analysis to allow our network of publishers and advertisers to understand the performance of the advertisements that are being displayed;
(d) Understand trends and your needs;
(e) Improve your experience across multiple browsers and devices (such as smartphones, tablets, computers, etc); and
(f) Carry out other purposes that may be described in this Privacy Policy or on our website.
2.2.2 Browser/Technical information. We may collect non-personally identifiable information that your browser automatically sends to us when you are visiting a publishers’ website and using our Ad and Video Network Service, such as:
(a) Page URL;
(b) Information regarding the browser such as the type and version of the browser;
(c) Type of device and operating system used;
(d) Network carrier information;
(e) Non-precise location information (limited to the country and city);
(f) Mobile application information; and
(g) User interactions with the Ads, such as clicks or video views.
2.3 LIMITED PERSONAL DATA
We may additionally from time to time collect your Personal Data to support the delivery of our Ad and Network Service or for advertising campaigns, such information is listed below.
2.4 SOCIAL MEDIA AND SHARING OF CONTENT
In order to give users the ability to share advertisement content that they see with their family, friends, and other users, we may work with social media tools, services and networks provided by social media companies like Facebook or Twitter to allow for such sharing across social media platforms. You may be required to provide your personal data to use such tools. You may also be required to log-in to your social media account to share the content, in which case you will be brought under the third-party service and the third-party provider’s privacy policy would apply to the information that you provide. Please note that we are not responsible for the collection, use and disclosure of personal data by these third-party service providers, and it would be prudent for you to read their privacy policies governing your personal data.
2.5 ADVERTISING CAMPAIGNS
In some instances, our advertiser clients may ask us to run advertising campaigns which, as part of the promotion or services offered, may require the participant or user to provide his or her personal data. Where a participant or user voluntarily provides his or her personal data to AnyMind, AnyMind shall be entitled to collect, process, store and disclose such personal data for and on behalf of its client for the purposes for which it was collected. However, AnyMind’s client remains primarily responsible at all times for the collection, use and disclosure of the Personal Data.
Other types of collection of personal information. We generally do not collect Personal Data that do not fall within the two categories mentioned above. In the instance where we collect your Personal Data, it is on a voluntary basis and we will obtain your prior consent every time.
We use a variety of technologies to collect and use the Activities Information as below.
(a) Web tags: Our web tags collect information from your browser when you visit our publishers’ websites, including information regarding the browser, device information, and clickstream information. Such information is then transmitted to us via the web tags.
(b) Cookies: A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies are sent to your browser from a website and stored on your computer's hard drive upon your consent. Cookies transmit information about your preferences and history such as your browser type, search preferences, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. It does not contain any data that will allow us to determine your actual identity.
(c) Pixels: A pixel is a microscopic graphic image embedded on a webpage. It collects information regarding the use of the webpage containing the pixel.
(d) Third-party services: We may employ or engage third-party service providers or third-party technology providers to provide us with ad campaign or site analytics, ad verification data, aggregate data of users, hosting services, and such other technology or services for our Ad and Video Network Service. These third-party providers may utilize web tags, cookies, pixels, and/or such similar technologies to obtain non-personally identifiable information or aggregated data, and carry out data analytics on such data, in order to deliver targeted advertising more suited to your interests. You may wish to check the privacy policy and opt-out options governing such third-party cookies, web tags, pixels of other similar technologies. This Privacy Policy does not extend to the usage of such third-party cookies, web tags, pixels of other similar technologies used by these third-parties.
(e) Advertiser Client trackers: The advertisers we work for may also use web tags, cookies, pixels, web beacons and/or such similar technologies in their advertisements. We may from time to time collect aggregate, non-personally identifiable information from them for the purposes described at Section V below. However, we do not seek to actively identify you from such data collected from our advertiser clients. This Privacy Policy does not extend to the usage of such technologies by our advertiser clients.
4.1 We use information collected mainly to allow us to provide more relevant advertisements to you, or to produce advertising reports to our customers.
4.2 We will use your Personal Data for the purposes in which it was collected and consented by you. If we intend to use your Personal Data for a materially different purpose, we will inform and obtain your prior consent accordingly.
5.1 ANYMIND GROUP
We may disclose the Activities Information and Personal Data to any member of our group of companies, including our subsidiaries, ultimate holding company, and all its subsidiaries, insofar as reasonably necessary for the purposes, and on the legal bases set out in this policy. Information about our group of companies can be found here.
5.2 THIRD-PARTY SERVICE PROVIDERS
5.2.1 We may employ or engage third-party service providers or third-party technology providers to provide us with an ad campaign or site analytics, ad verification data, aggregate data of users, hosting services, and other similar technology or services for our Ad and Video Network Service. In order for these third parties to provide us with such technology or services, we may share Activities Information with them.
5.2.2 These third parties have access to the Activities Information only to perform the tasks stated in this Policy. We do not provide these third parties with Personal Data.
5.3 INTERNATIONAL TRANSFERS
We may transfer to and maintain on computers located outside of your state, province, country or other governmental jurisdiction the Activities Information and Personal Data where the data protection laws may differ from those in your jurisdiction.
5.4 COMPLIANCE WITH LEGAL OBLIGATION
AnyMind may be required to disclose your information or other information collected by us in order to comply with the law and other legal obligations. Under these circumstances, AnyMind will disclose the requested information. However, we will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
In the event, you click on a link that leads you to a third-party website, any Personal Data you provide on the third-party website is subject to the third-party’s privacy policy. We are not responsible for the privacy and security of these third-party websites. We encourage you to be familiar with their data protection policies and practices before providing your information to these third-party websites.
7.1 We regard breaches of your privacy and breach of information very seriously and have put in place reasonable security measures to protect the information it collects. These measures include the training of employees on good data protection practices and confidentiality; dealing with Personal Data on a need to know basis; and securing Personal Data against misuse, loss, unauthorized access, modification or disclosure.
7.2 Notwithstanding the measures and steps taken by AnyMind to protect the information it collects, we cannot guarantee its absolute security. This is especially so with respect to cyber-attacks, spy-ware, hacking, and viruses. Accordingly, you will not hold us liable for any unauthorized access, modification, destruction or disclosure arising from such risks.
8.1 It is our responsibility to ensure that your Personal Data in our possession is accurate. AnyMind will take reasonable steps to ensure that the Personal Data which is inaccurate will be rectified without delay.
8.2 If you wish to update your Personal Data we hold about you, please submit your written request to our Data Protection Officer at the contact details below. We may require you to verify your identity.
9.1 AnyMind will retain the Activities Information or Personal Data (or any documents or records containing personal data, electronic or otherwise) for a period of 365 days to serve the purposes for which it was collected.
9.2 AnyMind will cease to retain the Activities Information or Personal Data or remove the means by which the Personal Data can be associated with particular individuals, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the information was collected, and is no longer necessary for legal or business purposes.
10.1 As a data subject, you have the right to withdraw consent given to us at any time during the period your Personal Data is retained by us. Furthermore, you have the right of access to your Personal Data and to request: copies thereof; disclosure of any personal data obtained by us without your consent; and correction of Personal Data that we have retained. We reserve the right to collect fees for copying or reproduction of data.
10.2 Further, you have the right to have your Personal Data deleted, including restriction of, or objection to, its processing. You also have the right to request that your Personal Data be transferred to another party.
10.3 To make a request to access the Personal Data we hold about you, please make a written request to the Data Protection Officer at the contact details provided below. We will require you to verify your identity and to specify what Personal Data you require. We will inform you of its processing of your request within 30 days from the date of its receipt.
10.4 The exercise of your rights must comply with law. We reserve the statutory right to refuse any demand.
11.1 You are allowed to withdraw consent to the collection, use and disclosure of your Personal Data at any time. You may withdraw your consent by submitting a written request to our Data Protection Officer at the contact details below. Upon receipt of request, we would require a reasonable time for your request to be processed and for us to notify you of the consequences for the withdrawal of consent. Depending on the nature and scope of the request to withdraw, we may not be able to continue providing our products or services to you.
11.2 Our primary ad-serving service providers also provide options to opt-out of their services. The instructions to opt-out may be found in their privacy notices found below:
(a) Xandr: https://www.xandr.com/privacy/platform-privacy-policy/#choices
(b) SMART: https://help.smartadserver.com/articles/Knowledge/Global-Privacy-Platform-GPP
(c) Google: https://adssettings.google.com
Please note that the above links may not be up to date, and you would be advised to check for the most up-to-date link.
11.3 In the event you have chosen to opt-out but use a different computer, browser or mobile device, you may have to renew your choice to opt-out.
12.1 NO SOLICITATION OF BUSINESS OR CONSUMERS FROM EUROPEAN UNION
12.1.1 We do not actively or intentionally solicit businesses or consumers in the European Union (“EU”).
12.1.2 Our publishers and advertiser clients are required to ensure that they do not send, transmit or forward any Personal Data or non-personally identifiable information from the EU or relating to EU citizens to us. If there is a need to provide us with such information, they will have to provide us with reason(s) beforehand for our assessment.
12.2 CHILDREN’S DATA
AnyMind does not create segments that target children below the age of 16 years old. It is not AnyMind’s intention to collect or process data from any child below the age of 16 years of age, except with the consent or authorization of the parent or guardian of the child.
We may change or update this Privacy Policy at any time. The effective date, as stated below, indicates the last time this Privacy Policy was materially revised. We advise you to visit this page occasionally to ensure that you are kept abreast of the changes made to this Privacy Policy.
If you have any queries or concerns regarding AnyDigital Premium Marketplace’s Privacy Policy, please contact our personal data protection officer by mail at #04-03 Anson House, 72 Anson Rd, Singapore 079911, Singapore or via email at dpo@anymindgroup.com.
Enacted on 1 January 2025
