Privacy Policy

Privacy Policy

Introduction

The integrity of individuals is a core priority for SunHaMedia.

AdsNextGen (https://adsnextgen.com/) is the official CPA network operated and owned by SunHaMedia, and serves as its commercial trading name. For the purpose of this Privacy Policy, the term “AdsNextGen” shall refer to the platform, while “SunHaMedia” refers to the legal entity managing and processing data through it.

Advertisers, publishers, and other customers (hereafter the “Client” or “Clients”) who contract with AdsNextGen for services involving the processing of personal data of Users (hereafter the “User” or “Users”) must be able to trust that such data is handled in accordance with applicable privacy laws and regulations.

This Privacy Policy is intended to help Clients and Users understand how SunHaMedia processes personal information through its AdsNextGen network. While this Policy does not address every possible scenario, it outlines the key privacy principles upheld by SunHaMedia.

This Privacy Policy was last revised on August 10th, 2023. SunHaMedia may update this Policy at any time without prior notice, for example, to ensure compliance with evolving legal requirements. You are encouraged to review this Privacy Policy each time you intend to share personal data with AdsNextGen.

Personal Data

“Personal data” refers to any information relating to a natural person or ‘Data Subject’ that can be used to directly or indirectly identify that person. This may include names, email addresses, phone numbers, IP addresses, and other unique identifiers.

SunHaMedia’s Role: Data Controller and Processor

A data controller determines the purposes, conditions, and means of personal data processing. A data processor processes personal data on behalf of the controller. SunHaMedia acts as both a data controller and data processor.

As a data controller, SunHaMedia relies on its Clients (advertisers and publishers) to obtain appropriate consent for data processing, as AdsNextGen is not in direct contact with Users.

As Data Controller:

  • When analyzing HTTP(S) headers for quality control and tracking. These headers include IP address, User Agent, OS, Timestamp, Browser, Carrier, Device Type, Brand, Model, Referrer, and Requested Page.
  • When a publisher’s tracking pixel is implemented, and AdsNextGen sends Session ID or publisher cookie.

As Data Processor:

  • When receiving data via tracking pixels on advertiser sites (e.g. Session ID or AdsNextGen cookie).
  • When receiving optional data for quality control, such as Order ID, Amount, Currency, IP address, or Carrier.
  • When publishers send traffic optimization data in Sub-IDs.

Collection of Personal Data

From Clients:

  • Registration: Clients may be required to provide personal and corporate information (e.g. name, address, email) to access services.
  • Sales & Contact Forms: Data collected via online forms for outreach and onboarding.
  • Network Applications: Data submitted by prospective Clients applying to join AdsNextGen.
  • Customer Support: Data collected during inquiries about services or policies.

From Users:

  • HTTP(S) header analysis for quality control and tracking.
  • Data from advertiser tracking pixels (Session ID, AdsNextGen cookie).
  • Optional quality control values (Order ID, IP address, etc.).
  • Sub-ID data for traffic optimization.

Use of Personal Data

SunHaMedia processes all personal data in accordance with this Privacy Policy and applicable laws. Data is collected only as necessary to deliver services defined in agreements.

Clients:

  • Service delivery and access management.
  • Account administration and payment processing.
  • Internal analytics and platform optimization.
  • Direct marketing (where permitted).
  • Compliance with legal obligations.

Users:

  • Service performance and quality assurance.
  • Traffic analysis and optimization.
  • Marketing (where permitted).
  • Compliance with legal obligations.

No personally identifiable information (PII) of Users is stored permanently on our servers.

Disclosure and Transfer of Personal Data

Personal data may be transferred within SunHaMedia and to trusted third parties under service agreements. These third parties are contractually obligated to process data securely and only per SunHaMedia’s instructions.

User metadata is stored in the United States. No PII is stored permanently. Some Client data may be shared with business partners within or outside the US/EU/EEA. When applicable, SunHaMedia will require recipients to adhere to this Privacy Policy’s principles.

SunHaMedia complies with all relevant US federal and state laws, including the CCPA and privacy laws in California, Virginia, Connecticut, Colorado, and Utah.

Privacy Rights of US State Residents

If you are a resident of California, Virginia, Connecticut, Colorado, or Utah, you have the following rights under applicable state laws:

  • Right to Know: Request categories and specifics of personal data collected, used, disclosed, or sold.
  • Right to Deletion: Request deletion of your personal data.
  • Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights.
  • Right to Opt-Out: Opt-out of the sale or use of sensitive personal data.

Requests can be submitted to: jenny@adsnextgen.com or via Microsoft Teams. Identity verification may be required.

Consent and Withdrawal

SunHaMedia obtains consent where legally required, either directly or through Clients. If you do not agree to this Policy, please do not provide personal data.

You may withdraw consent at any time by emailing: contact@adsnextgen.com with subject: “Withdrawal of Consent” and your full contact information. Upon withdrawal, SunHaMedia will cease processing your data and erase it.

Right to Access and Rectification

You may request:

  • A copy of your personal data.
  • Correction of inaccurate or outdated data.

Email: contact@adsnextgen.com for data access or updates.

Security Measures

SunHaMedia implements reasonable technical and organizational safeguards to protect data from unauthorized access. Access is limited to authorized personnel and vetted contractors bound by confidentiality agreements.

All data is secured with Google Cloud infrastructure.

Cookies

Our Site uses cookies to improve user experience and facilitate session management. Registered Clients may receive cookies for login and session functionality.

Users may disable cookies in browser settings, but certain services may not function properly.

Age Restriction

People under 18 years old (or the legal age in your jurisdiction) are not permitted to use our services on their own. This Privacy Policy makes no provision for their use of the site, and we do not knowingly collect personal data from minors.

Contact Us

If you have any questions about this Privacy Policy, you may contact us using the information below:

SunHaMedia / AdsNextGen (Same legal entity and shared address)

Data Protection Officer (DPO): Roussaud Costas Duran (https://www.rcd.legal)