1. Introduction
2. Who we are
3. what data we process
4. What data is collected from you
5. What is the legal basis for the processing of your Personal Information based
6. How is your Personal Data used
7. Who has access to your Personal Data
8. Third Party Service Providers we work with
9. Retention of your Personal Data
10. How you can opt-out of processing and access or update your Personal Data
11. Security precautions in place to protect the loss, misuse or alteration of your Personal Data
12. Age requirements
13. Transferring your information outside of Europe
14. Privacy Policies of our supply partners for your reference.
15. Your Data Protection Rights
16. Updates to this Policy

1. Introduction - Affle Iberia, S.L. - Privacy Policy

At Affle Iberia, S.L. ("Mediasmart"), we take the fundamental rights of end-users and employees (the “Data Subjects”) very seriously and we are committed to protecting and respecting your privacy and your privacy rights.

This is our Privacy Notice for our Self Serve Programmatic Platform for incremental growth (the “Platform”) as well as the general website you find at https://mediasmart.io, and it explains when and how we collect Personal Data about people who:  a)  visit our website and/or use our services through website and on-line servers and  b) are exposed to the advertisements (“Ads”) provided by our clients in which we enable the technical serving process. It also explains how we use such Personal Data, the conditions under which we may disclose it to others and how we intend to keep it secure. It describes the processing activities carried out by Mediasmart, the purposes for which these activities are performed and the legal basis that Mediasmart relies upon to justify these processing activities.

Mediasmart participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Mediasmart’s identification number within the framework is 193.

We keep this Privacy Policy under regular review and its scope and contents might evolve from time to time. Please kindly check this page occasionally to ensure that you’re up to date with any changes. Mediasmart’s Privacy Policy was last updated on August, 2024.

Any questions regarding this Policy and our privacy practices should be sent by email to:  legal mediasmart.io

2. Who we are

We are Mediasmart Mobile, S.L. (“Mediasmart”) a software as a service platform for advertisers, agencies and companies seeking to dramatically improve their digital advertising strategies. We are a member of the Affle group. We provide our services to our clients, who are either advertisers themselves or media buyers. The Platform helps our clients display relevant digital advertising to end users who interact with them. We are a Spanish limited liability company, with tax ID number B-86329638 and our registered address on: Calle Garcia de Paredes 12, 1ºB, 28010, Madrid.

3. What data do we process?

We process very limited information about you (your “Personal Data”).

Such Personal Data is collected in the following ways:

  • - On our website and servers, when you visit and browse through it and/or use any of the services we provide through it such as accessing “bsmart”) our advertising bidding platform. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we could possible collect it from you:
  • Contact Data: This covers any personal data provided to us in our ‘Contact Us’ form, such as your name, email, country and any personal data contained in your message. We encourage you to avoid adding unnecessary personal data to your contact message.
  • Marketing and Communications Data: This is your preference for receiving marketing information and other communications from us for our marketing newsletters. It will include your name and email address. Note: Any marketing emails will comply with the CAN-SPAM Act, where applicable.
  • Job Application Data: Containing information such as your name, location, email, CV data and cover letter. We use this to decide if you are a suitable candidate for our vacant roles. Generally, we receive applications via direct email, however your data will be processed in line with this privacy policy.
  • Technical Data: This is your IP address, browser type and version, time zone settings, location, operating system and platform, and other technological identifiers on the device(s) you use to engage with us. We use this for analytics, with your consent, as well as to improve site functionality. Cookies are used for this purpose.
  • User Account Data: We will collect limited Personal Data in order to register your account for the BSmart platform. E.g., Username, email address.
  • - On behalf of our clients: We collect Personal Data when you use any of our providers products or services which use Ads within them. What this means is that when you use an App or visit a web page from a digital device (for example, a smartphone) that shows Ads, chances are that such advertisement impressions have been “purchased” by companies using our software-as-a service-platform in order to serve you such Ads. Our platform collects limited Personal Data to the extent and in the way explained in this policy (please see next section). Generally, we will collect and process your data on behalf of our clients only when we have your consent to do so - i.e., via a lawful cookie banner. If you click “Accept”, your data will be shared with us. Mediasmart relies on the IAB TCF standard, and ensures we are using the latest release to guarantee our compliance with EU data protection regulations.Mediasmart will also process certain data based on legitimate interest (see section 5 below for more information on lawful bases), such as “Special Purpose 3” of the IAB TCF. Special Purpose 3 gathers limited information in order to save and communicate your privacy choices. E.g., your choice to ‘consent’ or ‘reject’ advertising cookies are stored as a string of characters and shared with us. This ensures that Mediasmart, and our clients, are respecting your privacy choices. We cannot identify an individual based on special purpose 3. If you have any questions about our use of legitimate interest of special purpose 3, please contact us at legal@mediasmart.io.

4. What data is collected from you?

The Personal Data we collect through our website/servers and/or on behalf of our clients include cookies and online identifiers from the device used to run the App or browse the web pages in which the Ad impression was served and might include the IP address being used at the time the Ad was served and other ancillary information such as: the size of the ad space, the operating system and version running in your device, the category of the app or website where it was served, or the approximate location of the device.

‘Cookies’ are small text files containing pieces of information (often including a unique identifier), sent to your device and stored on your hard drive to allow a website to recognize you each time you visit. They collect statistical data about your browsing actions and patterns and do not generally identify you as an individual.

Device identifiers shared by applications have been linked to cookies, in the sense that they are used for the same purpose in mobile and connected TV apps.

Please note that while these cookies and device identifiers are regarded as Personal Data and while we process and protect them as such, they do not specifically and automatically identify you as an individual, but simply the device you are using. While it would be extremely difficult for us or for any third Party to know about your specific identity using this information, at any time you might choose to: erase or remove your browser cookies as well as reset the on-line identifier of your mobile devices rendering all and any personal data linked to such devices obsolete. For more information, please refer to our Cookie Policy.You may also find more information in our opt-out section below.

We rely on the following separate bases to lawfully process your information:

i. Usage of the bsmart platform: We need to process our clients’ Personal Data in order to be able to provide the access to the bsmart platform in accordance with the Platform’s Terms of Service. This processing is necessary to perform the contract between our clients and us. This refers specifically to any personal data required to create your user account and complete your profile.Data collected and processed for this purpose is limited to: Username, password, role, email, name and (optional) a profile image.

ii. We may process Personal Data where necessary for the purposes of our legitimate interests or the legitimate interests of third parties to collect and use your Personal Data, except where those legitimate interests are overridden by your rights or interests or fundamental rights and freedoms.

iii. In some cases, such as for our marketing newsletters, contact form and cookies on our website, we rely on your explicit consent that we obtain indirectly from our clients or partners, connected directly to our Platform or using technology connected to the Platform. For example, on our website you may submit a form via HubSpot to contact us to request an integration. Additionally, we may have a legal obligation to collect data.

6. How is your Personal Data used?

Website and server cookies are used internally to measure how the different sections from our website work, to track your browsing through it, and also in order to find out where is the traffic coming from at any moment in time.

Bsmart cookies are used to identify you within the platform and in order to provide you with our Services, including information about how you interact with the platform and those of our third-party partners and information that allows us to recognize and associate your activity across devices and Services. This information may include information such as IP address, cookie information, browser version, operating system type and version, mobile network information, device settings and software data.

With regard to device identifiers collected on behalf of our clients, we use them to:

  • - allow our clients to target their advertisement campaigns, for example, the product an advertiser is promoting may work only in a given country and a certain operating system, and in order to properly manage the campaign our system needs to read the IP address (to understand in which country the Ad will be served in) and the operating system;
  • - allow our clients to generate user segments (what we call “audiences”) based on your previous interactions with their advertising campaigns;
  • - ensure we respect your privacy choices (such as ‘consenting’ or ‘rejecting’ advertising cookies) via IAB TCF Special Purpose 3, please refer to Section 3 for more information;
  • - allow our clients to target identifiers based on them being part of certain user segments (those segments may have been created with our platform or a different one);
  • - allow our clients to track whether or not you have engaged with their Ads.

Our clients may analyze your personal information to create a profile of your interests and preferences so that Ads can be better targeted to you. In these instances, the client is generally your Data Controller and shall provide you with appropriate information regarding their processing. We may also use your Personal Information to detect and prevent fraud.

Allowing our customers to target user segments is what we call “Interest Based Advertising”.

We will hold your Personal Data on our systems for as long as is necessary for the relevant activity (we have set a general maximum limit of six (6) months).

For more specific information, please refer to section 3 (“What data do we process?”) of this Privacy Policy.

7. Who has access to your Personal Data?

We do not share any Personal Data obtained by way of the cookie usage of our website. With regards to the information obtained through your usage of bsmart, we may share your information with third-party partners used to provide you with add-on services to bsmart if and when you request them.

Regarding to device identifiers obtained on behalf of our clients, we may need to share your Personal Data with certain partners at the very moment our system has to decide whether or not to buy some specific ad space as programmed or instructed by our clients. For example, if our client is working with a Data Provider, and targets a campaign to user segments created by that Data Provider, we may need to check with said Data Provider whether your identifier is in the targeted user segment before we decide to try and buy the Ad slot.We will only share personal data with these third parties when we receive appropriate and lawful consent to do so from the app or website that owns the ad placement.

Our clients will have access to your information when they have purchased that impression and thus have served you an Ad.

Mediasmart is a part of the Affle group of companies. Affle is a group of controlled undertakings which, in accordance with the GDPR Art. 4 (19), Recital 37 + 48, allow for a legitimate interest in sharing certain personal data within the group. This data sharing is limited to what is necessary, and primarily applies to your application to a job position at Mediasmart. Your data will not be shared with other agencies within the group or with no purpose. If your data is to be shared, you will be provided with notice.

8. Third Party Service Providers we work with:

  • - AdSquare (www.adsquare.com), a mobile data exchange who can work as a Data Provider for our customers
  • - Liveramp (liveramp.com), an identity platform leveraged by brands and their partners to power people-based marketing.
  • - Amazon Web Services (aws.amazon.com), provider of cloud-based architecture is the host of our DSP software.
  • - Invoiced.com (https://www.invoiced.com/), a B2B invoicing network to facilitate payments.
  • - Google Big Query ((cloud.google.com/bigquery), an enterprise data warehouse that hosts some of the DSP data for analysis and reporting.

However, when we use third party service providers, we disclose only the Personal Information that is necessary to deliver the service and we have arrangements in place that require them to keep your information secure and not to use it for any other purposes. Please be reassured that we will not release your information to third parties beyond the Ads serving process we’ve described, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

We may share certain information from you collected in connection with our services with brands, agencies and other interested third parties, to help them identify commercial opportunities where legally permissible.

9. Retention of your Personal Data

We will retain your Personal Data for as long as it is necessary to fulfil our purposes described in this Policy, unless a longer retention period is required or permitted by law. In no case will any Personal Data be retained for longer than six months. We may retain aggregated, anonymized data for analytical purposes indefinitely and we commit not to re-identify this data.

10. How you can opt-out of processing and access or update your Personal Data

 10.1 Website browsing and/or server cookies

You may refuse or accept cookies from websites at any time by choosing the appropriate settings on your browser. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please be aware that should you choose to decline all cookies, you may not be able to sign in or use other features of our website that depend on cookies.

Information about the procedure to follow in order to enable or disable Cookies can be found at:

For more information about other commonly used browsers, please refer to http://www.allaboutcookies.org/manage-cookies/. Please note, that the above links and processes will change from time to time, as technologies and browsers evolve. We aim to keep the links active, but you may always find further information by searching for help or support articles from your particular device/browser regarding cookie opt-out.

To opt-out of participating in Google Analytics data follow the instructions: https://tools.google.com/dlpage/gaoptout.

In order to access to a detailed list of cookies used by Mediasmart, please refer to our Cookie Policy.

Some of our clients have their own opt-out mechanisms that are linked from their sites. You should review the Privacy policies of those companies for these opt-out links, if you no longer wish to receive targeted advertising from a particular company.

 10.2 Interest-based advertising Personal Data

You may opt-out of this interest based advertising process altogether

Please note that you have the choice to opt-out from all Interest Based Advertising activities by changing the settings on your Android or iOS phone or tablet (we never use your identifiers if you use mobile devices with any other operating system).

Your iOS or Android mobile device provides a “Limit Ad Tracking” or “Opt out of interest-based advertising” setting. When you have opted out using this setting on a device, we will not allow our clients to use Personal Data collected from that device for any targeting purposes, nor to create any user segments.

You can find the setting for your mobile device by following the directions below:

  • - iOS Device iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting iOS 6 Go to your Settings >Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting More information about the iOS setting can be found here. Android Device.

  • - Android devices with OS 2.2 and up and Google Play Services version 4.0 and up: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising” If you’ve turned on Limit Ad Tracking on your iOS device or the Opt out of interest-based ads on your Android device, you can restore interest-based ads by turning the settings off.

When you opt out, you may still see the same number of Ads on your mobile device; however, these ads may be less relevant because they won’t be based on your interests, neither Ads bought with our platform, nor with any other platform. We may continue to serve you Ads based on other non-Personal Data, such as ads related to the content of the application you are using.

What this means is that by opting out of from all Interest Based Advertising you will not remove advertising from the pages you visit; instead it means the ads you will see may not be matched to your interests.

Opting out of interest based advertising just from Ads managed by Mediasmart:

You can opt-out of interest-based advertising coming ONLY from our clients by providing us your advertising identifier (IDFA if you have an iPhone or GAID if you have an Android phone). In order to do this, please use the tool we have developed for this purpose by visiting this link.

By providing us with these identifiers, we can also tell you what user segments in our system your identifiers are currently part of. You may request to be deleted from certain user segments and we shall communicate your request to the corresponding client.

11. Security precautions in place to protect the loss, misuse or alteration of your information

We take this matter seriously and we’re continuously evolving our platform to make sure data integrity and data security are always a priority. We use reasonable organizational, technical, administrative and physical safeguards to protect the Personal Data we collect and process. Our platform and servers use encryption techniques for storage and transmission of data.

12. Age requirements

We are concerned to protect the privacy of children. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with Personal Data.Mediasmart listens to signals that indicate viewers of ads are minors, in compliance with COPPA and similar international legislations. We offer controls to customers to ensure that they have to actively opt-in to targeting children. In these instances, as the Controller, the customer is responsible for ensuring appropriate processing of the data of minors. We ensure, via contractual measures, that our customers - when targeting minors - adhere to applicable data protection legislation.

13. Transferring your information outside of Europe

Please kindly note that your Personal Data may be transferred to countries outside the European Economic Space. This may take place if any of our servers located in a country outside of the European Union (“EU”). These countries may not have similar data protection laws to the ones we have in the EU. By providing us with your Personal Information in the way described in this Privacy Policy, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this document. We will implement appropriate safeguards to protect your Personal Data, such as requiring the recipient to comply with the Standard Contractual Clauses, EU-US Data Privacy Framework (US only), or another lawful and approved transfer mechanism. If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

IMPORTANT: If you do not agree with this transfer of Personal Data outside of Europe, you may opt-out of our processing of your Personal Data by using the procedures explained in section 10 above: “How you can opt-out of processing and access or update your Personal Data".

14. Privacy Policies of our supply partners for your reference

This Policy does not address, and except as otherwise described in it, we are not responsible for, the privacy, information, or other practices of any third parties, including our vendors or any other third party operating any site or service to which the Platform links.

We maintain an updated list of supply partners at the following link. If you have questions about how our supply partners process your data, please contact them directly.

You may also contact us regarding our engagement with our supply partners. 

15. Your Data Protection Rights

You have the following data protection rights:

  • - You have the right to request access to or that we change, update, or delete your Personal Data at any time.

  • - If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time.

  • - The right to opt out of receiving marketing communications from us. 

  • - If you are a resident of the European Economic Area (EEA), you may also have the following rights:

    • - The right to object to processing of your Personal Data, restrict processing of your Personal Data, or request portability  of your Personal Data. To exercise these rights email legal mediasmart.io; and

    • - The right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.  

You can exercise your rights at any time by contacting us at legal mediasmart.io. We will respond to your request in accordance with our obligations under applicable privacy laws..

For information on your US rights, please refer to our US Privacy Supplement, found here.

16. Updates to this Policy

We will review and update this Privacy Policy periodically and will note the date of its most recent revision at the top of this Policy. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes prior to such changes taking effect, if required by applicable data protection laws. We encourage you to review this Policy frequently to be informed of how Mediasmart is protecting your information.

Contact us

Mediasmart commits to resolving any questions or queries with regard to this Privacy Policy and our collection, use of transfer of your Personal Data. Please send any questions or queries via email to: legal mediasmart.io

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