Scope and roles (controller and processor)
This page applies to data processing on the adPluga platform. We act as controller for data processed for our own purposes (accounts, billing, security) and as processor when we process data on customers' behalf (e.g., audiences and events from the customer's inventory), in which case a Data Processing Agreement (DPA) applies.
Legal bases
We process data based on performance of the contract, legitimate interests (security, fraud prevention and measurement, duly balanced), consent (non-essential cookies/tracking) and compliance with legal obligations — under GDPR art. 6 and LGPD arts. 7 and 11.
Data processed and purposes
We process account, billing, usage/technical and ad-delivery data (pseudonymized identifiers, hashed IP, user-agent, approximate location) to provide, measure and protect the Service. Full detail is in the Privacy Policy.
Retention
We keep data for as long as the purposes and legal obligations require: the IP and user-agent hashes of delivery events and audience members are deleted after 365 days, and technical logs after 7 days. After these periods, we delete or anonymise.
International transfers
When we use processors outside the EEA or Brazil (e.g. cloud, payments), we ensure transfers under EU Commission Standard Contractual Clauses (SCC) and/or guarantees under LGPD Art. 33.
Subprocessors
The list of active subprocessors is in the Data Processing Agreement (adpluga.com/en/legal/dpa, §7). We give at least 30 days' notice before adding or replacing a subprocessor.
Automated decisions and profiling
We use automated processing for invalid-traffic (IVT) detection and to rank ads (relevance/eCPM ranking). These processes do not produce significant legal effects on individual data subjects; you may request clarification and human intervention.
Incident notification
In case of a personal data breach posing risk to data subjects, we notify the competent authority and affected subjects within applicable deadlines (72h under GDPR, reasonable time under LGPD).
Data Protection Officer (DPO)
To exercise any right or clarify questions about the processing of your data, contact: privacidade@adpluga.com. We respond within the applicable legal deadline (up to 15 business days under LGPD, up to 1 month under GDPR).
Review and version
We review this page periodically and whenever there are material changes to our practices or the legal framework. The last-updated date reflects the version in force.