Adgrowth Privacy Policy

Last updated: July 31, 2025

Adgrowth, operated by ADACTION INTERNET S.A., a private legal entity registered under CNPJ No. 31.599.488/0001-49, located at Avenida Angélica, 2133, Conjunto 32, Consolação, São Paulo - SP, CEP 01227-200, Brazil, is committed to protecting the privacy and personal data of its users, clients, and partners. This Privacy Policy outlines how we collect, use, store, share, and protect information on our programmatic advertising platform (Demand-Side Platform - DSP), accessible at www.adgrowth.com.

1. Introduction

Adgrowth is a programmatic media platform that enables the automated purchase and management of digital advertisements, leveraging data to optimize advertising campaigns. This policy covers the use of our platform, including interactions with advertisers, publishers, data providers, and other partners, in compliance with Brazil's General Data Protection Law (LGPD - Law No. 13.709/2018), the General Data Protection Regulation (GDPR) of the European Union, the California Consumer Privacy Act (CCPA), and other applicable international data protection laws.

2. Information We Collect

We collect various types of information to provide and improve our services, including:

2.1. Personal Data

• Registration Information: Name, email, phone number, company, job title, and other data provided by users when creating an account or contacting us.
• Contact Information: Information provided when interacting with our support team or specialists, such as emails sent to [email protected].
• Usage Data: Information about how you use our platform, including campaign preferences, settings, and interactions with the interface.

2.2. Advertising Campaign Data

• Segmentation Data: Anonymized or aggregated data used for ad targeting, such as demographic, behavioral, contextual, or geolocation data, provided by partner data providers or collected anonymously.
• Performance Data: Campaign statistics, such as impressions, clicks, conversions, and delivery reports, which do not directly identify individuals.

2.3. Technical Data

• Cookies and Similar Technologies: We use cookies, pixels, and other technologies to track ad interactions and enhance user experience.
• Navigation Data: IP address, device type, browser, operating system, and other technical information automatically collected when accessing our site or platform.

3. How We Use Your Information

We use the collected information to:

• Provide and Operate the Platform: Manage accounts, process transactions, and deliver ads efficiently.
• Optimize Campaigns: Use data for precise targeting to enhance the effectiveness of advertising campaigns.
• Improve Our Services: Analyze platform usage to enhance features and user experience.
• Ensure Security: Protect against fraud, ensure brand safety, and comply with legal obligations.
• Communication: Send updates, technical support, or responses to inquiries.
• Legal Compliance: Meet legal or regulatory requirements, including those under LGPD, GDPR, and CCPA.

4. Sharing of Information

Adgrowth shares information only in the following circumstances:

• With Business Partners: Anonymized or aggregated data may be shared with data providers, ad exchanges, publishers, and other partners to execute advertising campaigns.
• With Service Providers: Vendors assisting with services such as hosting, data analysis, and technical support, always under confidentiality agreements.
• For Legal Requirements: When necessary to comply with legal, judicial, or regulatory obligations.
• With Consent: Personal data may be shared with third parties when you expressly authorize us.

We do not sell personal data to third parties.

5. Legal Basis for Data Processing

Data processing by Adgrowth is based on the following legal grounds:

• Consent: When you voluntarily provide personal data, such as during account creation (LGPD Art. 7, I; GDPR Art. 6(1)(a)).
• Contract Performance: To fulfill contractual obligations related to platform use (LGPD Art. 7, V; GDPR Art. 6(1)(b)).
• Legitimate Interest: To optimize campaigns and improve services, provided it does not harm your rights (LGPD Art. 7, IX; GDPR Art. 6(1)(f)).
• Legal Obligation: To comply with regulatory or legal requirements (LGPD Art. 7, II; GDPR Art. 6(1)(c)).

6. Data Security

We implement technical and organizational measures to protect your information, including:

• Data encryption in transit and at rest.
• Restricted access controls to internal systems.
• Brand safety solutions to ensure secure campaign delivery.
• Continuous monitoring against cyber threats.

While we strive to protect your data, no system is entirely immune to breaches. In the event of a security incident, we will notify affected individuals as required by LGPD, GDPR, and other applicable laws.

7. Your Rights

Under LGPD, GDPR, CCPA, and other applicable laws, you have the following rights over your personal data:

• Access: Request information about the data we hold about you.
• Correction: Update or correct inaccurate data.
• Deletion: Request deletion of your data, except where legal retention obligations apply.
• Portability: Receive your data in a structured format.
• Objection: Object to data processing based on legitimate interest.
• Consent Withdrawal: Withdraw consent for data use, where applicable.
• Opt-Out of Sale (CCPA): Opt out of the sale of personal information (note: Adgrowth does not sell personal data).

To exercise these rights, contact us at [email protected].

8. Opt-Out of Tracking Mechanisms

9. Cookies and Tracking Technologies

We use cookies and similar technologies for:

• Functionality: Ensure proper platform operation.
• Performance: Analyze site and platform usage for improvements.
• Advertising: Deliver targeted ads based on anonymized data.

You can manage cookie preferences through your browser settings. Disabling cookies may limit some platform functionalities.

10. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. Anonymized campaign data may be retained longer for statistical analysis.

11. International Data Transfers

Some of our partners or vendors may be located outside Brazil. When data is transferred internationally, we ensure compliance with LGPD, GDPR, and other applicable laws, using contracts with data protection clauses or other safeguards, such as Standard Contractual Clauses (SCCs) under GDPR.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. The latest version will always be available at www.adgrowth.com/privacy-policy. We will notify users of significant changes via email or through our platform.

13. Contact

For questions, requests, or further information about this policy, contact our Data Protection Officer (DPO):