Platform Privacy Policy

1.     Introduction
AdFixus Pty Ltd ("AdFixus", "we", "us", or "our") specialises in privacy-focused digital identity solutions designed to comply with stringent data privacy regulations, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA). This Privacy Policy outlines how the AdFixus Platform manages, processes, and safeguards Visitor Data. This Privacy Policy specifically applies to the AdFixus Platform and its operation. Information collected when visiting the AdFixus websites or through the course of our regular business is covered separately in our general Privacy Policy (https://www.adfixus.com/privacy-policy).

2. Definitions

- AdFixus Identifier:
A secure, encrypted identifier unique to each browser and client, created and managed by AdFixus.

- Personally Identifiable Information (PII): Information that directly or indirectly identifies an individual, as defined within the GDPR, including name, email address, telephone number, identification number, location data, online identifiers, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.

- Fingerprinting: Techniques used to probabilistically identify Visitors by aggregating device characteristics such as IP addresses or other information routinely exposed by browsers. This approach differs from deterministic methods, which consistently generate identifiers without relying on probabilistic or fingerprinting techniques.

- Event Data: Information about Visitor interactions, such as ad impressions, clicks, or conversion events.

- Visitor: An individual accessing or interacting with a client's digital properties where the AdFixus Platform is utilised, identified solely at the browser or application level without reference to personal identity.

- Visitor Data: Information collected or generated through a Visitor's interaction with a client's digital properties. This includes the AdFixus Identifier, Event Data, and any associated interaction information captured by the Client.

3. What is the AdFixus Platform
The AdFixus Platform refers to the suite of technologies and services provided to our clients, including digital publishers and advertisers, enabling them to recognise Visitors and deliver personalised content and advertising in a legally compliant manner. We do not operate digital properties used by Visitors, beyond the website we use to promote our products (that is www.adfixus.com), nor do we function as an advertiser, data aggregator, or broker.

4. AdFixus Platform Overview
The AdFixus Platform includes: 

- AdFixus Identify: Generates a secure, privacy-first persistent identifier consistently across participating Client owned domains / websites.

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AdFixus Match: Allows deterministic matching of identifiers without processing PII, using multi-layer encryption involving Client and AdFixus owned keys, managed by AdFixus.

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AdFixus Stream: Securely transmits Event Data between advertisers and publishers in real-time without PII, storing Event Data solely and securely within cloud storage owned and operated by the applicable Client.

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AdFixus Measure: Provides privacy-compliant analytics for advertising effectiveness without third-party cookies.

- AdFixus Link: Generates non-persistent identifiers supporting Stream and Measure functionalities, varying over time to prevent consistent identification.

5. Data Collection and Processing Principles
We do not collect, store, or commercialise PII. Identifiers created by us (AdFixus Identifiers) are deterministic and stored exclusively in Visitors' browsers and client-controlled environments. Our agreements require clients to adhere to applicable privacy laws, including obtaining Visitor consent where necessary. The AdFixus Platform allows Visitors to opt-out, respecting their privacy preferences. Client Data stored within the Platform is limited to that needed for system monitoring, performance and security, irreversibly de-identified to ensure Visitor anonymity.

6. Cookies and Similar Technologies
The AdFixus Platform uses first-party cookies and may utilise localStorage, sessionStorage, and eTags to store information securely on Visitor browsers. Cookies expire after one year but refresh upon each visit. Visitors can opt out via client-provided mechanisms, supported by opt-out functionality provided by the AdFixus Platform.

7. Purpose and Legal Basis for Data Processing
We produce and process identifiers on behalf of Clients to allow them to perform functions such as audience targeting, measurement and matching, without requiring us to store any identifiable Client Data. Clients define and maintain the legal basis for data processing, typically involving Visitor consent or legitimate interest, as defined within GDPR Article 6(1)(f).

8. Data Security
We maintain robust security measures, including ISO27001:2022 certification, external security audits, and penetration testing, all pertaining to the AdFixus Platform. In addition, data processed via the AdFixus Platform is encrypted at multiple stages (including at-rest and in-transit) using robust industry-standard cryptographic protocols.

9. Data Sharing and Transfers
We do not transfer personal data to third parties. When identifiers are shared between Clients, they are securely transformed to prevent identification across different Clients. Event Data is transmitted real-time to exclusively to Client owned cloud storage, with all processing done in memory.

10. Data Retention
Persistent identifiers created by AdFixus Identify are stored as cookies which expire after one year and refresh upon interaction. Transient identifiers generated by AdFixus Link are updated at least weekly, preventing reliable re-identification.

11. Profiling Visitors
We do not create, maintain, or monetise visitor profiles, nor do we capture any data within our platform for such purposes. Any visitor profiles maintained by our Clients are based solely on data they independently collect and manage. This may include the AdFixus Identifier, which is stored exclusively by clients, not by AdFixus. We may, on behalf of our clients, perform data analysis to support them in using their data. In such instances, we only utilise and store information that has been anonymised and cannot be linked by us to any individual.

12. Data Erasure and Correction
We do not directly manage personal data. Requests regarding data access, correction, deletion, or restriction must be directed to the Client.

13.  Breach Notification
In accordance with the Australian Privacy Act 1988 (Cth) and the Notifiable Data Breaches scheme, we commit to promptly informing Clients of any suspected or confirmed data breach involving Visitor Data. Should such a breach pose a risk of serious harm to visitors, we will assist our Clients in meeting their obligations to notify affected individuals and the Australian Information Commissioner (OAIC) within required timeframes.

14. Changes to This Privacy Policy
We may periodically update this Privacy Policy. Updates willbe published here, and Visitors and Clients alike are encouraged to review regularly.

15. Contact Us
For questions or concerns, please contact:
AdFixus Pty Ltd
privacy@adfixus.com 

Last updated on 17 March 2025

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