AdHub Media

Article 1 - Premises

1. These general terms and conditions (“General Terms”) govern the relationship between AdHub Media S.r.l. (“AdHub Media”), with registered office at Via Paolo da Cannobio, 9, 20122 Milan, VAT number IT13542920965, and any party accessing the website www.adhubplatform.com and interested in publishing on their own website the advertisements sold by AdHub Media (“Publisher”). AdHub Media S.r.l. and the Publisher are also referred to individually as a “Party” and collectively as the “Parties”.
2. The General Terms are accepted by the Publisher on the Website, through the “point and click” mechanism (i.e., by checking a box), following the registration of their details required to access the service referred to in Article 2 below.
3. By accepting the General Terms, the Publisher declares that: a) they possess a valid individual or corporate VAT number to invoice the service; b) they are at least 18 years old; c) they are the owner or manager of the website(s) communicated to AdHub Media at the time of registration on which they intend to publish the advertisements subject to this relationship (“Website(s)”); d) they have the authority to accept the General Terms; e) they will not publish any content of a pedopornographic, violent, or otherwise illegal nature on the Website(s).
4. AdHub Media reserves the right to terminate the General Terms for just cause if the Publisher does not meet the requirements set forth in the preceding Article 1.3, within 5 (five) working days from the acceptance pursuant to point 1.2.
5. Regarding the contractual relationships between the Parties, the latter agree that, in the event of the execution of separate and distinct agreements from these General Terms, the provisions contained in such agreements, where they have the same content as these General Terms and/or where they conflict with them, shall prevail in any case over the General Terms, limited to the clauses of the General Terms with the same content and/or that conflict with the provisions of the aforementioned agreements.

Article 2 - Service

1. By accepting the General Terms, the Publisher entrusts AdHub Media, which accepts, with the task of granting the sale (“Service”) to third parties (“Advertisers”) of the advertising spaces available on the Website(s) for the publication of advertisements (“Advertisements”) in the form of, by way of example but not limited to, banners, text links, videos.
2. For the purposes of the Service, the Publisher grants AdHub Media the mandate to carry out, with its own organization and at its own expense, the activities of researching, promoting, and acquiring advertising orders from Advertisers related to the Advertisements and to collect the related payments.
3. To use AdHub Media’s Service, the Publisher accepts the insertion on the Website(s) of the codes related to the advertising formats (“Tags”) of AdHub Media. The Tags are necessary for the publication of AdHub Media’s Advertisements on the Website(s) and for the reporting of visits to the Website(s) by the Publisher’s users.

Article 3 - Publisher’s Commitments

1. For the duration of these General Terms, the Publisher undertakes to:
2. In case of breach of any of the commitments under the preceding Articles 3.1.6, 3.1.8, and 3.1.10, AdHub Media reserves the right to suspend the Service for a period sufficient to allow the Publisher to remedy the breach and in any case not exceeding 30 (thirty) days, as well as the right to withhold the revenues referred to in Article 5 below, as an advance for the potential compensation for damages due from the Publisher to AdHub Media for the same breach. If the breach is not remedied within the aforementioned period, the express termination clause under Article 12 shall apply.

Article 4 - Publisher’s Liability

1. The Publisher is solely responsible for the Website(s), its content, and the materials published therein. To this end, for the duration of the General Terms, the Publisher declares and warrants to AdHub Media that the Website does not and will not contain:
2. The Publisher declares and warrants that all information provided at the time of registration referred to in the preceding Article 1.3, in order to use AdHub Media’s Service, is correct and truthful. In particular, the Publisher expressly acknowledges being solely responsible for the correct indication—and constant updating—of the bank details (IBAN) required at the time of the aforementioned registration, indemnifying and holding AdHub Media harmless in case of errors by the Publisher and/or illegal or fraudulent conduct by third parties against the Publisher, which prevent the due payment of the fee referred to in Article 5 below.

Article 5 - Fees and Payments

1. Regarding the revenues generated from the auction sale of the spaces on the Website(s) to Advertisers for the publication of Advertisements, the Parties agree that the Net Revenues will be recognized to the Publisher according to the revenue share agreed at a minimum of 60%. Net Revenues mean the gross revenue collected by AdHub Media for the sale of services related to the Advertisements on the Website(s), net of: (a) discounts and any agency commissions, (b) technical platform and ad-serving costs, (c) VAT and other taxes.
2. The Publisher can view the amounts accrued, indicated in Euros, daily from their control panel. However, since the advertising spaces on the Website(s) may also be sold in currencies other than the Euro, the Publisher acknowledges that the amounts displayed may vary due to the applicable exchange rates applied daily. In any case, the amounts due to the Publisher will be calculated based on the exchange rates in effect on the 10th day of the following month.
3. Unless otherwise agreed between the Parties, AdHub Media undertakes to make payments to the Publisher through the following methods: (i) during the following month, the Publisher will find in their control panel, in the “Payments” section, the consolidation of the revenues accrued in the previous month, provided that the Publisher has accrued an amount exceeding €50.00 (fifty/00); (ii) the Publisher undertakes to issue and upload the related invoice to the panel; and (iii) AdHub Media, after verifying the correctness of the issued invoice, undertakes to pay the amount of such invoice to the Publisher within 60 (sixty) days end of month from the invoice date. For clarity regarding the above points, the Parties agree that any amounts below €50.00 (fifty/00) accrued by the Publisher will be accumulated with any amounts possibly accrued by the Publisher in the following months until the aforementioned minimum amount of €50.00 (fifty/00) is reached, so that AdHub Media can make the payment of such minimum amount pursuant to this Article 5.3.
4. In case of termination of these General Terms, for any reason, any credits of the Publisher of at least €50.00 (fifty/00) will be paid by AdHub Media, upon the Publisher’s request, within 90 (ninety) days. However, the Publisher forfeits the right to request payment of such residual credits exceeding €50.00 (fifty/00) after 2 (two) years from the termination of these General Terms. In case of forfeiture of the Publisher’s right, the Publisher’s credit will be definitively acquired by AdHub Media, which may freely dispose of such amounts.
5. In any case, the Publisher acknowledges and expressly accepts that AdHub Media will make payments due to the Publisher only after collecting the corresponding amounts from the Advertisers.
6. For the purpose of quantifying the fees, AdHub Media’s systems for detecting impressions and clicks will be exclusively valid. Conversely, fees possibly accrued in violation of the preceding Article 3.1.9 will not be deemed valid and will not entitle the Publisher to receive the related payment from AdHub Media.

Article 6 - Duration and Termination

1. These General Terms have an indefinite duration and are effective from the date of acceptance.
2. Without prejudice to the provisions of the preceding Article 6.1, the Publisher may at any time terminate these General Terms with written notice, to be sent also via email to publishing@adhubmedia.com, with a notice period of at least 15 (fifteen) working days, subject to the provisions of Article 10 below.
3. Without prejudice to the provisions of the preceding Article 6.1, AdHub Media may terminate these General Terms, without the obligation to provide explicit reasons, by giving notice via email to the Publisher, with a notice period of at least 15 (fifteen) working days, subject to the provisions of Article 10 below.

Article 7 - Limitation of AdHub Media’s Liability

1. Except in cases of willful misconduct or gross negligence, AdHub Media assumes no liability regarding the use, availability, timeliness, or possible deletion of the Service. In particular, AdHub Media offers no guarantee as to the accuracy, truthfulness, and completeness of the Advertisements and exercises no control over them. Moreover, AdHub Media offers no guarantee regarding: (i) the identity, legal capacity, seriousness of intent, or other characteristics of the Advertisers; (ii) the quality, legality, and safety of the products and/or services subject to the Advertisements; (iii) the truthfulness and accuracy of the descriptions provided.
2. The Publisher uses AdHub Media’s Service under their sole responsibility, and AdHub Media cannot be held liable, contractually or extra-contractually, for losses or damages arising from the use of the Website and the Service, including, without limitation, any damage (direct, indirect) and any loss (of income, profits, goodwill, data, contracts, use of money), as well as losses or damages arising from business interruption, caused by the use and/or impossibility of use, by the results of the use of the Website. In particular, AdHub Media offers no guarantee as to the results obtained by the Publisher through the use of the Service and, specifically, regarding the level of impressions or clicks generated by the Advertisements on the Website(s).

Article 8 - Amendments to the General Terms

1. AdHub Media may at any time amend the General Terms due to unforeseen technical, economic, and managerial needs and due to changes and reforms of applicable laws and regulations.
2. In case of amendments under the preceding Article 8.1, the Publisher acknowledges and agrees that:
3. 8.3
  These General Terms and the rights and obligations arising therefrom may be assigned, in whole or in part, by AdHub Media to companies affiliated with it, such as, by way of example but not exhaustively, AdHub Media S.r.l. S.B. with registered office in Milan 20122, Via Paolo da Cannobio, 9, VAT number IT13542920965, by simple communication to the Publisher and without the need for any authorization by the latter.

Article 9 - Advertising

1. For the duration of the General Terms, the Publisher grants AdHub Media the right to use their name and/or logo and/or trademark in presentations, marketing materials, client lists, financial reports, lists of client websites. The license under this Article is granted free of charge and on a non-exclusive basis.

Article 10 - Communications Between the Parties

1. Unless otherwise indicated, the Parties agree that any communications between them may be validly sent via email.
2. Email communications to AdHub Media must be sent to the following address: publishing@adhubmedia.com
3. The Publisher agrees to receive via email service communications related to the fulfillment of these General Terms (request for increased impressions, campaign updates, new formats, etc.) also sent through third-party platforms.
4. Email communications under this Article 10 will be deemed delivered on the day they were sent, provided that the Party sending the email does not receive a “delivery failure” notification from the other Party.
5. Without prejudice to the provisions of the preceding point 4, the Publisher acknowledges and accepts that, if they have not properly updated their email address, any communications sent by AdHub Media under this Article 10 to the email address provided by the Publisher at the time of acceptance of the General Terms will be deemed perfected on the date they are transmitted by AdHub Media, even if the Publisher has changed their email address without notifying AdHub Media, and/or if such email address is no longer “active”.

Article 11 - Intellectual Property

1. The Publisher acknowledges that the intellectual and/or industrial property rights of AdHub Media related to and/or connected with the Service and the activities under these General Terms (“IP Rights”) are the exclusive property and/or under the full control of AdHub Media and will remain the exclusive property and/or under the full control of AdHub Media for the entire duration of the Contract and also after its termination.
2. The Publisher undertakes, at any time during the duration of the General Terms, or thereafter, directly or indirectly, to:

Article 12 - Express Termination Clause

1. Without prejudice to any further rights provided by law, AdHub Media has the right to terminate these General Terms with immediate effect, pursuant to and for the purposes of Article 1456 of the Italian Civil Code, by written notice to the Publisher, containing the declaration of intent to avail itself of this express termination clause, in case of breach by the Publisher of any of the following articles: 3, 4, 11.
2. In case of termination of the General Terms due to the Publisher’s breach of the commitments under the preceding Article 12.1, AdHub Media reserves the right to withhold from the revenues possibly due to the Publisher an amount as partial or total compensation for damages, without prejudice to AdHub Media’s right to claim compensation for any further damages possibly suffered.

Article 13 - Privacy

1. For the provision of the Service, the Publisher communicates to AdHub Media data and information of a personal nature pursuant to and for the purposes of EU Regulation 2016/679 (“Regulation”). Such data and information are processed by AdHub Media in compliance with the Regulation and the privacy notice provided by AdHub Media pursuant to Article 13 of the Regulation, available at the following link [http://www.adhubplatform.com/privacy/], which is an integral part of these General Terms.

Article 14 - Miscellaneous

1. If one or more provisions of the General Terms, or parts thereof, are declared invalid, illegal, or otherwise unenforceable by law or judicial decision, the remaining provisions, or parts thereof, will remain binding and/or enforceable between the Parties. In this case, the Parties undertake to agree in good faith on the introduction of an alternative provision as similar and compatible as possible with the one found invalid, null, or otherwise unenforceable.
2. The delayed, partial, or non-exercise of any right under the General Terms, or the tolerance of a breach by the other Party, will not in any way prejudice the Party entitled to such right, or suffering such breach, unless the same has expressly waived it in writing.
3. Notwithstanding any other provision of the General Terms, if AdHub Media is unable to fulfill its contractual obligations due to fires, wars, strikes, embargoes, government regulations or other civil or military authorities, omissions and negligence of carriers or suppliers, vandals or hackers, failures or malfunctions of third-party networks, telecommunications equipment, websites, software and hardware, or other technologies beyond the reasonable control of AdHub Media (“Force Majeure”), the period for the performance of the relevant obligations will be extended for the period of delay or impossibility to perform due to the specific Force Majeure events. It is understood that the persistence of a Force Majeure situation for more than sixty (60) days will allow the Publisher to terminate the General Terms, without any compensation or indemnity being due from AdHub Media.
4. The Parties acknowledge and agree that, by accepting these General Terms, they do not intend in any way to establish between themselves relationships of agency, commercial representation, association, or joint venture. Each Party acts individually as an independent entrepreneur and may not, under any circumstances, act in the name or on behalf of the other Party, nor claim against the latter any rights and/or claims contrary to the nature of these General Terms or based on relationships not explicitly provided for herein.

Article 15 - Governing Law and Jurisdiction

1. These General Terms are governed by Italian Law.
2. For any dispute relating to the General Terms, including its execution, interpretation, and/or termination for any reason, the exclusive jurisdiction will be the judicial authority of the Court of Milan, to the exclusion of any other potentially concurrent jurisdiction.

1) Definitions
Cookies, Personal Data, Service Agreement, Privacy Notice, Regulation, Service, Additional Services, Website, Processing, Users, Registered Users.

Details

1.1 Cookies: Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. On each subsequent visit, the browser sends the cookies back to the originating website. Cookies may be stored only for the duration of a specific website session (i.e., session cookies) or for a longer period, independent of the session (i.e., persistent cookies).
1.2 Personal Data: any information relating to an identified or identifiable natural person, directly or indirectly, by reference to a name, identification number, location data, online identifier, or elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
1.3 Service Agreement: the agreement signed by AdHub Media with Registered Users for the provision of the Service.
1.4 Privacy Notice: this document, comprising the privacy notice on the processing of Personal Data and the cookie notice.
1.5 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.6 Service: service for optimizing advertising campaign spaces on websites made available by Registered Users.
1.7 Additional Services: option to submit spontaneous job applications to work with AdHub Media and to request contact information from AdHub Media by filling out the form available on the Website.
1.8 Website: this website.
1.9 Processing: any operation or set of operations performed on Personal Data, such as, by way of example, collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, restriction, erasure, or destruction.
1.10 Users: users of the Website, including Registered Users.
1.11 Registered Users: users registered on the Website who have a personal account to access the services offered by AdHub Media under the Service Agreement.

2) Data Controller
AdHub Media S.r.l.

Details

The Data Controller referred to in this Privacy Notice is AdHub Media S.r.l. (“AdHub Media”), with registered office at Via Paolo da Cannobio, 9, 20122 Milan, VAT number IT13542920965. Any request from Users/Registered Users regarding the Processing of their Personal Data by AdHub Media (including the exercise of the rights referred to in point 8 below) must be addressed to AdHub Media by mail at the registered office or by email at the following address info@adhubmedia.com.

3) Purposes and Legal Basis for Processing
a) browsing the Website: consent;
b) provision of Additional Services: consent;
c) access to personal accounts by Registered Users: Service Agreement;
d) improvement of the Website: legitimate interest.

Details

AdHub Media collects and uses Users’/Registered Users’ Personal Data for the following purposes:
a) Allow browsing on the Website, primarily through the use of Cookies.
➢ The collection of Personal Data for the purpose referred to in letter a) is governed by the Cookie Notice, available at the following link https://www.adhubplatform.com/informativa-cookie/, which AdHub Media recommends reading.

b) Provide Additional Services to Users.
➢ The collection of Personal Data for the purpose referred to in letter b) is necessary for the User to access the Additional Services, and any refusal prevents the User from using the Additional Services. This Processing is based on the User’s free, specific, informed, and unambiguous consent, expressed through a statement or positive action (e.g., flag) on the Website. Withdrawal of consent may be exercised at any time by following the instructions in point 7 letter a) of this Privacy Notice.

c) Allow Registered Users to access their personal accounts to use the Service.
➢ The collection of Personal Data for the purpose referred to in letter c) is necessary for Registered Users to use the Service, in accordance with the terms and conditions of the Service Agreement, and any refusal prevents Registered Users from using the Service. This Processing is based on the execution of the Service Agreement.

d) Perform statistical analyses on Website usage to improve the Website. Where possible, AdHub Media uses anonymized Personal Data (Personal Data that does not identify or make Users identifiable) for this purpose.
➢ The Processing referred to in letter d) is based on the legitimate interest of AdHub Media, consisting of the benefit the Company may derive from providing a Website that facilitates navigation and improves the User experience, which AdHub Media considers to prevail over the Users’ right to privacy. Objection to this Processing (where it does not involve anonymized data) may be exercised at any time by following the instructions in point 7 letter g) of this Privacy Notice.

4) Methods of Data Collection
a) Personal Data collected automatically by the Website (via Cookies);
b) Personal Data entered into the Website by Users;
c) Personal Data explicitly communicated to AdHub Media by Users through offline methods.

Details

AdHub Media collects Personal Data through the following methods:
a) Personal Data collected automatically by the Website: this includes Personal Data collected automatically by the Website through, but not limited to, Cookies (for further information, AdHub Media recommends reading the Cookie Notice provided below);
b) Personal Data entered into the Website by Users: this includes Personal Data provided by Users to access Additional Services, for example, through the contact form available at the link: https://www.adhubplatform.com/contatti/.
c) Personal Data explicitly communicated to AdHub Media by Users through offline methods: this includes Personal Data directly communicated to AdHub Media employees and collaborators by Users through methods other than the Website.

5) Categories of Recipients of Personal Data
Employees, collaborators, third-party IT service providers, third parties contractually linked to AdHub Media (for the provision of Services).

Details

Personal Data is processed by AdHub Media and/or by third parties, selected for reliability and competence, to whom it may be communicated where necessary or appropriate, provided that such parties are within the European Union. In particular, AdHub Media informs Users that Personal Data may be processed by, and/or communicated to:
a) employees and/or collaborators of AdHub Media;
b) third-party service providers necessary to ensure the functioning of the Website (e.g., hosting service providers, IT technicians);
c) third parties providing Website navigation data analysis services;
d) third parties contractually linked to AdHub Media, necessary for the provision of the services under the Service Agreement (e.g., AdHub Media's regional partners).

6) Retention Period for Personal Data (or Criteria for Determination)
a) Personal Data from the "contact" form: 3 months from receipt of the request;
b) Personal Data for the account: for the duration of the Service Agreement.

Details

Personal Data is retained by AdHub Media for the period 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 under point 8 letter a) or the right to object under point 8 letter g) is exercised, AdHub Media retains Personal Data for the following periods:
a) Cookies: for the purpose referred to in point 3 letter a), please refer to the Cookie Notice;
b) Personal Data collected from the "contact" form: for the purpose referred to in point 3 letter b), for a period of 3 months from receipt of the contact request, to verify whether the User requires further assistance on the same topic. As an exception to this period, if a complaint or grievance is submitted through the "contact" form, the User's Personal Data will be retained for the period referred to in letter d) below;
c) Personal Data for managing Registered Users' accounts: for the purpose referred to in point 3 letter c), for the duration of the Service Agreement;
d) in any case, AdHub Media is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to the information necessary to comply with legal obligations and to allow AdHub Media to establish, exercise, or defend a legal claim.
Upon expiry of these periods, AdHub Media will automatically delete the collected Personal Data or irreversibly anonymize it.

7) Rights of Users/Registered Users
Withdrawal of consent, access to Personal Data, rectification or completion of Personal Data, erasure of Personal Data, restriction of Processing, objection to Processing, portability of Personal Data, data breach, complaint to competent authorities

Details

Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Privacy Notice, each User/Registered User has the right to:
a) with reference to the Processing referred to in point 3 letter b), withdraw consent at any time without affecting the lawfulness of Processing, by sending an email to AdHub Media or exercising the opt-out in AdHub Media's commercial communications (cf. Art. 7 of the Regulation);
b) request access to their Personal Data and information about the related Processing, as well as a copy in electronic format, unless the User/Registered User specifically requests otherwise (cf. Art. 15 of the Regulation);
c) request rectification and/or completion of their Personal Data without undue delay (cf. Art. 16 of the Regulation);
d) for specific reasons (e.g., unlawful Processing, withdrawal of consent, absence of the purpose for Processing), request erasure of their Personal Data without undue delay (cf. Art. 17 of the Regulation);
e) in specific cases (e.g., inaccuracy of Personal Data, unlawfulness of Processing, exercise of a legal claim), request restriction of Processing (Art. 18 of the Regulation);
f) receive their Personal Data in a structured, commonly used, and machine-readable format and, consequently, exercise the right to data portability and transmit such data to another controller (Art. 19 of the Regulation);
g) with reference to the Processing referred to in point 3 letter d), object at any time to the Processing of their Personal Data by sending an email to AdHub Media (cf. Art. 21 of the Regulation);
h) be informed by AdHub Media without undue delay of any breaches or unauthorized access by third parties to its systems containing Personal Data (so-called data breach - Art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country where they reside, work, or where they believe their rights have been violated (cf. Art. 77 of the Regulation);
For further information on the terms and conditions for exercising the rights granted to Users/Registered Users, the latter may consult the text of the EU Regulation published at the following link http://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX:32016R0679&from=IT, or contact AdHub Media as provided in point 2 of this Privacy Notice.

1) Definitions
General Terms, Cookies, Advertising Campaigns, Personal Data, Privacy Notice, Profiling, Publisher, Regulation, Additional Services, Service, Website, Publisher Website, Processing, Users.

Details

1.1 General Terms: general terms and conditions governing the provision of the Service.
1.2 Cookies: Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. On each subsequent visit, the browser sends the Cookies back to the originating website or to another website. Cookies may be stored only for the duration of a specific website session (i.e., session Cookies) or for a longer period, independent of the session (i.e., persistent Cookies).
1.3 Advertising Campaigns: advertising campaigns sold by AdHub Media on Publisher websites.
1.4 Personal Data: any information relating to an identified or identifiable natural person, directly or indirectly, by reference to a name, identification number, location data, online identifier, or elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
1.5 Privacy Notice: this document, comprising the privacy notice on the processing of Personal Data related to the Service.
1.6 Profiling: a form of Personal Data Processing, through automated—in whole or in part—procedures aimed at evaluating or predicting the Publisher’s preferences and interests.
1.7 Publisher: an adult natural person or legal entity, represented by its legal representative, who uses the Service offered by AdHub Media to publish advertisements sold by AdHub Media on their own website.
1.8 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.9 Service: organization and management of Advertising Campaigns on Publisher Website spaces through native, video, and display ads.
1.10 Website: this website.
1.11 Publisher Website: website owned and/or managed by the Publisher where the Service is provided.
1.12 Data Controller: AdHub Media S.r.l.
1.13 Processing: any operation or set of operations performed on Personal Data, such as, by way of example, collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, restriction, erasure, or destruction.
1.14 Users: users of Publisher Websites.

2) Data Controller
AdHub Media S.r.l.

Details

The Data Controller referred to in this Privacy Notice is:
a) AdHub Media S.r.l., with registered office at Via Paolo da Cannobio, 9 - 20122 Milan, VAT number IT13542920965 (“AdHub Media”). Any request from the Publisher regarding the Processing of their Personal Data by the Data Controller (including the exercise of the rights referred to in point 8 below) must be addressed to AdHub Media by mail at the registered office or by email at the following address info@adhubmedia.com.

3) Purposes and Legal Basis for Processing
a) browsing the Website: consent;
b) registration on the Website: General Terms;
c) use of the Service: General Terms;
d) statistical analysis and market research, sending commercial and promotional communications by AdHub Media: express consent;
e) statistical analysis, market research, improvement of the Service and Website: legitimate interest.

Details

The Data Controller collects and uses the Personal Data of Publishers and Users for the following purposes:
a) allow browsing on the Website, primarily through the use of Cookies.
b) allow Publishers to register on the Website and create a personal account for monitoring the Service;
c) provide the Service to Publishers, including the management of administrative and accounting relationships resulting from the acceptance of the General Terms and the sending of communications strictly related to the provision of the Service, of a technical (e.g., notification of Advertising Campaign performance) and/or administrative nature (e.g., updates to this Privacy Notice).
➢ The collection of Personal Data for the purposes referred to in letters b) and c) is necessary for the Publisher to use the Service. Any refusal prevents the Publisher from using the Service as provided in the General Terms. These Processing activities are based on the Publisher’s acceptance of the General Terms and the related pre-contractual measures proposed by AdHub Media.
d) subject to optional consent, perform statistical analyses and market research, send informational and promotional materials, notify and invite to promotional initiatives by AdHub Media;
➢ The purpose referred to in letter e) is optional, and any refusal by the Publisher prevents them from benefiting from marketing activities (including direct and personalized marketing) by AdHub Media. These Processing activities are based on the Publisher’s free, specific, informed, and unambiguous consent, expressed through a statement or positive action (e.g., flag) on the Website. Consent may be withdrawn at any time by following the instructions in point 7 letter a) of this Privacy Notice.
e) Perform statistical analyses, market research, improve the presentation of the Service and the use of the Website by Publishers. Where possible, for this purpose, the Data Controller uses anonymized Personal Data.
➢ The Processing referred to in letter f) is based on the Data Controller’s legitimate interest, consisting of the benefit derived from offering Publishers services more aligned with their preferences during Website browsing, considering that it is also in the Publishers’ interest to use personalized services. For this reason, the Data Controller believes that the legitimate interest in developing and improving the Website and Service prevails over the Publishers’ right to privacy. Objection to this Processing (where it involves Personal Data and not anonymized data) may be exercised at any time by following the instructions in point 7 letter f) of this Privacy Notice.

4) Methods of Data Collection
a) Personal Data entered into the Website by Publishers;
b) Personal Data explicitly communicated to AdHub Media by Publishers;
c) Personal Data collected automatically by the Website (via Cookies).

Details

The Data Controller collects Personal Data through the following methods:
a) Personal Data entered into the Website by Publishers: this includes Personal Data provided, by way of example but not limited to, for browsing, registering, and accessing the Service offered on the Website;
b) Personal Data explicitly communicated by Publishers through offline methods: this includes Personal Data provided, for example, to AdHub Media's customer service (in case of contact requests) or collected during events and/or initiatives organized by the Data Controller or communicated when accepting the General Terms;
c) Personal Data collected automatically by the Website: this includes Personal Data collected automatically by the Website through, but not limited to, Cookies.

5) Categories of Recipients of Personal Data
Employees, collaborators, third-party service providers necessary for the use of the Service, third-party IT service providers, third-party technicians, third-party commercial service providers.

Details

Personal Data is processed by the Data Controller and/or by third parties, selected for reliability and competence, to whom it may be communicated where necessary or appropriate, provided that such parties are within the European Union. In particular, the Data Controller informs Publishers that Personal Data may be processed by, and/or communicated to:
a) employees and/or collaborators of the Data Controller;
b) third-party service providers necessary to ensure the functioning of the Website (e.g., hosting service providers);
c) third-party service providers necessary for the use of the Service (e.g., payment processors);
d) third-party IT and Website maintenance service providers;
e) third-party technicians providing Website navigation data analysis services;
f) subject to the Publisher's optional consent, third parties providing automated newsletter and/or any other type of commercial communication services, marketing, promotion, and analysis of consumption habits and choices.

6) Retention Period for Personal Data (or Criteria for Determination)
a) for the use of the Service: 10 years from the termination of the Service;
b) for the use of Additional Services and commercial purposes: 2 years.

Details

Personal Data is retained by AdHub Media for the period 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 under point 7 letter a) and/or the right to object under point 7 letter f) is exercised:
a) for the use of the Service, the Data Controller retains Personal Data for the duration of the General Terms and for an additional 10 (ten) years from the termination of the Service;
b) for commercial purposes, the Data Controller retains Personal Data for a maximum period of 2 (two) years from the Publisher's consent.
In any case, the Data Controller is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to the information necessary to comply with legal obligations and to allow the Data Controller to establish, exercise, or defend a legal claim and/or in tax audits.
Upon expiry of these periods, the Data Controller will automatically delete the collected Personal Data or irreversibly anonymize it.

7) Rights of the User and/or Publisher
Withdrawal of consent, access to Personal Data, rectification or completion of Personal Data, erasure of Personal Data, restriction of Processing, objection to Processing, portability of Personal Data, data breach, complaint to competent authorities.

Details

Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Privacy Notice, 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 affecting the lawfulness of Processing, by sending an email to AdHub Media, exercising the opt-out in commercial communications, or by deleting the account directly on the Website (cf. Art. 7 of the Regulation);
b) request access to their Personal Data and information about the related Processing, as well as a copy in electronic format, unless the User and/or Publisher specifically requests otherwise (cf. Art. 15 of the Regulation);
c) request rectification and/or completion of their Personal Data without undue delay (cf. Art. 16 of the Regulation);
d) for specific reasons (e.g., unlawful Processing, withdrawal of consent, absence of the purpose for Processing), request erasure of their Personal Data without undue delay (cf. Art. 17 of the Regulation);
e) in specific cases (e.g., inaccuracy of Personal Data, unlawfulness of Processing, exercise of a legal claim), request restriction of 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 their Personal Data by sending an email to AdHub Media (cf. Art. 21 of the Regulation);
g) receive their Personal Data in a structured, commonly used, and machine-readable format, with the right to portability to another controller without hindrance (Art. 20 of the Regulation);
h) be informed by AdHub Media without undue delay of any breaches or unauthorized access by third parties to its systems containing Personal Data (so-called data breach - cf. Art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country where they reside, work, or where they believe their rights have been violated (cf. Art. 77 of the Regulation);
For further information on the terms and conditions for exercising the rights granted to the User, the latter may consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX:32016R0679, or contact AdHub Media as provided in point 2 of this Privacy Notice.

8) Types of Cookies Used in the Service
The Data Controller uses Cookies, both its own and from third parties, within the Service to deliver targeted Advertising Campaigns on Publisher Websites.
Given that the Service uses Cookies, the Publisher is responsible for the information obligations imposed on website operators regarding Cookies and, in particular, the Publisher must inform Users of the presence on their Publisher Website, which hosts the Advertising Campaigns, of the Cookies indicated in this Privacy Notice.

Details

1. Third-party analytical Cookies
Google Analytics Cookies
a) Purpose:
these are Cookies provided by Google Inc. to monitor, in an anonymous and aggregated form, the statistical analysis of User traffic on the Publisher Website to adapt the Publisher Website to the results of such analysis, in line with the interests shown by the Users.

b) Data collected:
data related to the computer and the User's visit to the Publisher Website, which in no case allows AdHub Media to independently trace the User's Personal Data: (i) the domain from which the User accesses the Internet; (ii) the web address from which the User connected to the Website, if available; (iii) the date and time of connection to the Publisher Website, how long it lasted, and which pages were visited; (iv) the computer's operating system and the browser used by the User; (v) aggregated demographic details of Users accessing the Publisher Website.

c) Duration: session Cookies.
For further information on Google Analytics Cookies, the User may consult the following webpage: https://tools.google.com/dlpage/gaoptout.

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

AdHub Media profiling Cookies:
a) Name: 4wnet.data.cookie.
b) Purpose: AdHub Media uses profiling Cookies to improve the commercial experience of Users by offering content tailored to their tastes and personal habits, as well as sending advertising communications related only to products that are most relevant to the User's interests.
c) Data collected: data related to the computer and the User's visit to the Publisher Website, to create a "navigation profile" of the User based on their searches and the most frequently visited sections of the Publisher Website.
d) Duration: 30 days.
e) Place of Processing: Italy.

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

b) Data collected:
data and information on the User's online preferences and/or habits, such as searches performed, page load frequency, or activity on other third-party websites.

c) Duration:
session and persistent Cookies.

For further information on third-party advertising Cookies, the User may consult the following webpages:
i) SSP (Sell Side Platform): Platforms used by AdHub Media to monetize advertising spaces aggregated on Publisher Websites
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 used by AdHub Media to create/manage Advertising Campaigns with audience-based targeting
1. Nugg.ad: https://nugg.ad/en/privacy/general-information.html
2. Nielsen VisualDNA: https://www.visualdna.com/privacy-policy/
3. Nielsen Exelate: http://www.exelate.com/privacy/services-privacy-policy/
4. Neustar: https://www.neustar.biz/privacy/opt-out
5. Navegg: https://www.navegg.com/en/privacy-policy/
6. Audience Rate: http://www.audiencerate.co.uk/privacy.html
7. Omnicom Media Group: http://www.omgitaly.it/pdf/Cookies_Policy_OMG.pdf

9) Acceptance and Rejection of Cookies
Consent, banner, access to browser control panels, Your Online Choices service.

Details

The Publisher must 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 Website (via an immediate pop-up information banner).
Consent may be modified at any time.

That said, with reference to all Cookies in the Service, the User may modify the related settings according to the methods provided in the control panels of the browser used, such as, by way of 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 Privacy Notice), in addition to using the tools provided by the browser to enable or disable individual Cookies, the Data Controller informs that if the User does not wish to receive targeted advertisements (i.e., based on their online behavior) displayed by the Data Controller or the third parties mentioned above or unknown to the Data Controller, they may disable the display of such targeted advertisements by clicking here www.youronlinechoices.com/it/le-tue-scelte and configuring the setting for AdHub Media with the appropriate ON/OFF button. The above procedure refers to the specific browser the User is using to access the Publisher Website at a given time. If the User uses multiple browsers to navigate the Internet and does not wish to see targeted advertisements delivered by AdHub Media under any circumstances, they must repeat the above operation for each browser.

When the User disables the Data Controller's services, the latter places a technical Cookie in the User's browser to store their choice and respect it during subsequent online navigation. If this technical Cookie is deleted from the browser, the User must repeat the disabling procedure.
The above procedure will block only targeted advertisements delivered by the Data Controller and not those from any other third parties.

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