Privacy Policy
Ad Delivery Services

(For End Users of our Clients)

Click here for our Privacy Policy (Ad Delivery Services) in German

1. Introduction

This policy describes how Adnami ApS ("Adnami," "we," "us") processes minimal Personal Data when delivering high-impact advertising services. This policy applies to the technical delivery of ads via our specialized domains (including, but not limited to: functions.adnami.io, directive.adnami.io, rmb.adnami.io, tracker.adnami.io, and macro.adnami.io).

We are committed to transparency. We design our systems to minimize the processing of Personally Identifiable Information (PII) and ensure that any retained data cannot be traced back to individual end users.

2. Our Role and Accountability

To understand your rights, it is important to understand our legal role in the advertising ecosystem:

• Data Controller: The Publisher (the website or app you are visiting) is the Data Controller. They decide why data is processed and are responsible for establishing the legal basis (such as Consent) for showing you ads.
• Data Processor: Adnami ApS acts as the Data Processor (or "Service Provider" under CCPA). We process data solely on behalf of the Controller to technically deliver the ad creative.
• Strict Use Restriction: We are contractually prohibited from retaining, selling, using, or disclosing your Personal Data for any commercial purpose other than providing the contracted services to the Publisher. We do not sell your data.

3. How We Process Data (and Why)

When you visit a website that uses Adnami technology, we process limited technical data to ensure the ad loads safely and correctly. We do not build user profiles.

A. Data Categories & Retention

B. Purpose and Legal Basis

C. Cookies and Tracking

Adnami operates a cookie-less environment.

• We do not set cookies.
• We do not use Local Storage (LS) for tracking.
• We do not use fingerprinting techniques to identify users across different websites.

4. Data Sharing and Sub-Processors

We do not share your data with third parties for their own marketing purposes. We only share IP addresses with trusted infrastructure providers necessary to deliver the service.

Authorized Sub-Processors:

• Cloudflare, Inc. (US): Content Delivery Network (CDN) and Security. Used for bot detection and routing.
• Akamai Technologies, Inc. (US): Content Delivery Network. Used for caching and fast delivery.
• Microsoft Azure (EU): Hosting and cloud infrastructure.

Note: When your browser connects to our CDN partners (Cloudflare/Akamai), your IP address is visible to them for the split-second required to route the connection (approx. 7ms to 30ms).

5. International Data Transfers

Adnami is based in Denmark (EU). However, our Content Delivery Networks (CDNs) are global.

• Transfers: Minimal technical data (IP addresses) may be routed through servers outside the European Economic Area (EEA) or UK to ensure the fastest load times.
• Safeguards: We protect these transfers using the EU-US Data Privacy Framework (where the provider is certified) or Standard Contractual Clauses (SCCs) enforced by strict data processing agreements.

6. Your Privacy Rights

Because Adnami processes data transiently and does not store Personal Data, we never hold any data that can be linked back to you.

Consequently, any request to "Access" or "Delete" personal data is automatically fulfilled, as we hold no personal data to provide or erase. We do not maintain a database of user profiles, so there is no data to retrieve or destroy.

Legally, you retain the following rights regarding any processing that occurs:

• Right to Access & Know: You may ask what data is processed (Answer: None is stored).
• Right to Rectification: Correction of wrong data (Answer: Not applicable, as no data is held).
• Right to Deletion: Request erasure of data (Answer: Automatically fulfilled).
• Right to Withdraw Consent: If processing is based on consent.
• CCPA Rights (California): Right to opt-out of "Sale/Sharing" (Adnami does not sell/share data as defined by CCPA).

How to Exercise Rights: Please contact the Publisher (the website you visited). As the Data Controller, they can manage your consent preferences. If you contact Adnami, we will confirm that we hold no data regarding your request.

7. Additional Disclosures

Children's Privacy:
Our services are not directed at children under the age of 16. We do not knowingly collect or process personal data from children. If a Publisher targets children, it is their responsibility to configure our services in compliance with COPPA and GDPR-K.

Automated Decision Making:
We do not use your personal data for automated decision-making that produces legal or similarly significant effects (e.g., credit profiling).

8. Contact and Security

Security Measures:
We use enterprise-grade security, including SSL encryption for all data in transit and strict access controls for our infrastructure.

Contact Us:
If you have questions about this policy, please contact our Data Protection Officer (DPO):

• Email: dpo@adnami.io
• Post: Adnami ApS, Skinnergade 45, 3rd floor, 1159 Copenhagen, Denmark

Regulatory Authority:
You have the right to lodge a complaint with the Danish Data Protection Authority (Datatilsynet).

Updates:
This policy was last updated on November 20, 2025. We review it regularly to ensure compliance with evolving regulations. Significant updates to this policy will be communicated through our newsletter.