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. Adnami (TCF Vendor ID: 612) operates under a split-role model depending on the stage of data processing:

Joint Controller (Collection & Transmission): Adnami acts as a Joint Controller with the Publisher (the website or app you are visiting) during the initial stage of processing. This includes the collection and transmission of technical signals (such as your IP address) required to signal your privacy preferences and initiate the ad delivery process..

Independent Controller (Measurement & Security): Adnami acts as an Independent Controller for the specific purposes we have registered within the TCF. We determine the technical means and logic used to fulfil:

Purpose 7: Measure advertising performance (Legal Basis: Legitimate Interest or Consent).
Special Purpose 1: Ensure security, prevent and detect fraud, and fix errors.
Special Purpose 2: Deliver and present advertising and content.
Special Purpose 3: Save and communicate privacy choices.

Accountability & Data Stewardship: Although we act as a Controller, we apply strict "processor-like" restrictions to the data we handle. We are contractually prohibited from using this data to build cross-site user profiles, selling your data, or using it for any commercial purpose beyond the specific campaign measurement and delivery requested by our clients.

2.1 Why we use "Legitimate Interest" for Measurement

For TCF Purpose 7 (Measuring Ad Performance), Adnami relies on Legitimate Interest. We have determined that our interest in providing accurate, high-impact advertising metrics is balanced against your privacy rights for the following reasons:

Business Necessity: Adnami’s business model is built on providing "Attention" metrics. Without the ability to measure how long an ad is on screen or how a user interacts with it, we cannot fulfill our contractual obligations to Publishers and Advertisers.

Privacy-First Logic: Our "Sonar" measurement technology is designed to be non-intrusive. We do not use this data to identify you personally, track you across different websites, or build a behavioral profile.

Transient Processing: The technical data required for measurement (such as your IP address or device type) is processed "in-flight." We do not store these identifiers in a persistent database once the measurement event is recorded.

Transparency & Control: We provide full transparency through the IAB TCF and respect your Right to Object at any time through the privacy settings on this website.

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

Data Category

Description

Retention Period

Technical Data

IP Address, User Agent (Browser/Device type), Timestamp.

Transient (10–5000ms). Data is processed in memory to route the request and is then immediately discarded or anonymized.

Usage Data

URL of the page, page response times, ad rendering metrics.

Two-Tier Retention:

1. Aggregated Data: High-level performance statistics (e.g., total views) are processed immediately and retained for reporting.

2. Anonymized Logs: Raw event logs (scrubbed of direct identifiers) are retained for max. 3 months for technical verification, then permanently deleted.

B. Purpose and Legal Basis

Purpose

Details

Legal Basis (GDPR)

Technical Ad Delivery

Delivering the requested ad file to your device and ensuring it renders in the correct format (e.g., mobile vs. desktop).

Legitimate Interests: Essential for the technical functioning of the service.

Network Security

Detecting bot traffic, preventing ad fraud, and ensuring service stability.

Legitimate Interests: Ensuring network and information security.

Measurement & Verification

Verifying that the ad was successfully rendered on the device. This is technically necessary to confirm the service was delivered.

Legitimate Interests: Proof of delivery and technical verification.

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

As a participant in the IAB Transparency and Consent Framework (Vendor ID: 612), Adnami respects your rights under the GDPR and other global privacy laws. Because we act as a Controller for specific technical purposes, your rights are exercised as follows:

Right to Object (Legitimate Interest): Where we rely on Legitimate Interest (e.g., Purpose 7: Measurement), you have a direct right to object to this processing. You can exercise this by adjusting your preferences in the privacy settings (CMP) of the website you are visiting. Our systems are designed to detect and honor these "objection" signals in real-time.

Right to Withdraw Consent: For any processing based on your consent, you may withdraw that consent at any time via the website’s privacy settings.

Right to Access & Know: You have the right to know what categories of data we process. We process technical identifiers (IP address, User Agent) and privacy signals (TC Strings) transiently. However, because we do not store these identifiers or link them to a persistent profile, we typically cannot retrieve a specific history of your data.

Right to Deletion (Erasure): Adnami is "Private by Design." Because our data processing is transient—occurring in memory for only a few milliseconds—data is effectively "deleted" immediately after the technical delivery or measurement event is completed.

U.S. State Rights (CCPA/CPRA): We do not "sell" or "share" personal information for cross-context behavioral advertising as defined by California law. We act as a Service Provider for technical delivery while maintaining Independent Controller status for measurement purposes.

How to Exercise Your Rights:The most effective way to exercise your rights is through the Consent Management Platform (CMP) on the website you are visiting. When you change your settings there, a digital signal (TC String) is sent to Adnami, and we automatically update our processing to match your choice. If you have further questions, you may contact our DPO at dpo@adnami.io.

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 February 6, 2026. We review it regularly to ensure compliance with evolving regulations. Significant updates to this policy will be communicated through our newsletter.