These privacy policies are part of the General Conditions for the use of (hereinafter the “Website”), which are regulated in conformity with the provisions of Organic Law 15/1999 of 13 December on the Protection of Data of a Personal Nature (LOPD) and Royal Decree 1720/2007 of 21 December approving the Regulations for the Implementation of Organic Law 15/1999 (RLOPD).

All personal information provided to ADA Media LTD DBA Upads through the Website or through any other electronic means made available to users will be handled with the utmost confidentiality. We are committed to protecting and respecting the privacy of your data.


ADA Media LTD DBA Upads commits itself to respecting and facilitating interested parties exercising their rights recognized by regulations in matters of data protection and, in particular, the rights to access, rectify, cancel and oppose data. Said rights may be exercised by sending a request by post to Block A, George's Quay Plaza, George's Quay, Dublin 2, Ireland or by email at, attaching a photocopy of the DNI and specifying the right being exercised.


You guarantee and are accountable, in any case, for the information provided to be true, accurate and complete and you commit yourself to keeping it up to date. The registration of your data through the use of the signup form is mandatory, at least for those fields marked as such, and it shall imply that you have been informed and that you have provided your consent to the contents of this privacy policy. Not providing said data or the supply of incorrect data shall make it impossible for ADA Media LTD DBA Upads to handle requests correctly.

Moreover, ADA Media LTD DBA Upads commits itself to never using personal data for purposes different from those specified in this privacy policy nor transfer them unlawfully to third parties.


In compliance with the provisions of articles 5 and 6 of the LOPD, you are informed that the personal information you provide will be included in an automated file which is registered in the General Register of Data Protection, which ADA Media LTD DBA Upads is responsible for, and the use of which is meant to manage the consultations received and/or the commercial relationship that we maintain with you. Moreover, ADA Media LTD DBA Upads will use the information to send commercial information about the company, its products, services, offers and special promotions. You expressly consent to the use of your data for the purposes mentioned above, in conformity with the stipulations in the commercial communications section of these privacy policies.


In conformity with the provisions of Law 34/2002 of 1 July on Services for the Information Society and Electronic Commerce (LSSICE), the user may manifest the desire not to receive future commercial communication at any time by sending an email to, also, by following the instructions at the end of each commercial communication through the “unsubscribe” link.


This Website, as many others, uses cookies for a better experience while browsing the Internet. In this section, we inform you of what they are, which ones we use and how you can control them

What are cookies?

Cookies are small files with text and numbers placed in the hard drive of your electronic device when you visit a website. Cookies allow for the identification of a user from the rest in order to provide a better experience while browsing the Website at the same time as helping to improve it. Cookies may be classified according to their duration in session and permanent cookies and according to their source as first-party or third-party.


While visiting our Website, said third-party cookies are generated. Buttons for social networks (third parties) have been enabled on our Website with the purpose of allowing you to share contents of interest with your contacts or to follow us on social networks. Said third parties may set their own cookies with the purpose of customizing the application and measuring its functionality. Because of how these cookies function, ADA Media LTD DBA Upads cannot access them, in the same fashion that third parties cannot access the data of cookies used by us. Therefore, we recommend that you visit the websites of said third parties to understand their operation.

Controlling the use of cookies in your browser

You have the ability to accept or reject cookies. Currently, all browsers allow you to adjust the configuration to activate or deactivate the storage or cookies or reject them from specific sites. Generally, said parameters may be found in the “options” or “preferences” menu of the browser of your choice.

At any rate, we provide links below containing instructions that will help you to better understand said configuration adjustments in the most important browsers. We also inform you that you may find further information in the “Help” menu of the browser you use and at the following link:

Session cookies

These are those that are temporarily stored and expire immediately after leaving a website.

Permanent cookies

These are those that allow a website to remember you for subsequent visits, improving your experience while browsing through the functions you have installed.

First-party cookies

These are those installed by the website you are browsing itself.

Third-party cookies

These are those installed by websites different from the one you are visiting.



Google cookies

These cookies are used to identified the requesting account, filling the web history folder and providing personalized search results and suggestions.


This Data Processing Agreement ( DPA) is between Partner and ADA Media LTD DBA Upads (as defined under the Terms and Conditions) and forms an integral part of Terms and Conditions available at Partner and ADA Media LTD DBA Upads are hereinafter jointly referred to as the “Parties”. In the event of any conflict between this DPA and the Terms and Conditions, the terms of this DPA shall prevail. This Agreement only applies to the extent that the EU Data Protection Law applies to the Processing of Personal Data under this Agreement, including if (a) the Processing is carried out in the context of the activities of an establishment of either Party in the European Economic Area (“EEA”), and/or (b) the Personal Data relates to Data Subjects who are in the EEA and the Processing relates to the offering to them of goods or services or the monitoring of their behaviour in the EEA.

DEFINITIONS: “Controller” or “Data Controller” means the entity that determines the purposes and means of the Processing of Personal Data. “Processor” or “Data Processor” means the entity which Processes Personal Data on behalf of the Data Controller. “Data Subject” means the individual to whom Personal Data relates, including End Users.“ End User” means the end user of an internet connected device, such as a visitor to a web page, a user of a mobile app, or a user of an IoT device, or a visitor on advertisement or campaign webpage. “GDPR” means Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (also known as “General Data Protection Regulation”).“Personal Data” means any information relating to an identified or identifiable person as defined in Article 4.1 of the GDPR.“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction (“Process”, “Processes” and “Processed” shall have the same meaning).“Sub-Processor” means any Data Processor engaged by the Processor. “Services” means services provided by ADA Media LTD DBA Upads in accordance with the general legal terms mentioned above.

PROCESSING OF PERSONAL DATA: Under this DPA and with respect to Personal Data, Partner is the Data Controller or Processor and ADA Media LTD DBA Upads is engaged by Partner as Processor in respect to Personal Data, as applicable. The terms of this Agreement shall apply to either of the relations between the Parties regarding the Processing of Personal Data mentioned herein. Within the scope of this DPA, Partner hereby engages ADA Media LTD DBA Upads to collect, process and/or use Personal Data on Partner’s behalf. ADA Media LTD DBA Upads will only Process Personal Data on Partner behalf and in accordance with Partner instructions. The instructions from the Partner to Process Personal Data are the following: (i) Processing shall be carried out in accordance with this DPA, the Terms and Conditions and pursuant to the features and limitations of the applicable Services which ADA Media LTD DBA Upads provides to Partner; and (ii) Processing shall be carried out in compliance with other reasonable instructions provided by the Partner, where such instructions are consistent with the Terms and Conditions. ADA Media LTD DBA Upads will be under no obligation to comply with instructions that ADA Media LTD DBA Upads deems as violating applicable laws. ADA Media LTD DBA Upads uses the Personal Data solely to provide the Services in accordance with Terms & Conditions, i.e. in order to perform tracking services / serve End Users with interest–based advertising, as well as to measure the effectiveness of advertising campaigns and provide Partner with advertising reports. In that context, ADA Media LTD DBA Upads – on Partner demand – may also combine Personal Data from different sources in order to improve Services and integrate Services with external platforms, all of which will be conducted on Partner behalf. ADA Media LTD DBA Upads also processes Personal Data on Partner behalf and to serve Partner interests for the purposes of fraud prevention, bot detection, rating, analytics, viewability, ad security services. ADA Media LTD DBA Upads may also process data based on the extracts of Personal Data in aggregated and non-identifiable forms, including for the purposes of testing, development, control and operation of the Services. ADA Media LTD DBA Upads may process the following information on Partner behalf: IP addresses, language information, session-based browsing behaviour, header information, End User’s device-related data (such as the type or model of the device), operating system, wireless carrier providing communication services to such device, geographical location (geo-location) of the device, cookies, advertising identifiers of the device, as well as other information we may receive from Partner or from third parties engaged by the ADA Media LTD DBA Upads on Partner behalf, such as non-precise device location based on the IP address, device specifications and user’s interest’s information. Partner also authorizes ADA Media LTD DBA Upads to store and use cookies or pixel tags on End User’s device on behalf of the Partner in order to perform Services. Without derogating from any of the obligations of the Partner hereunder, the Partner shall not provide ADA Media LTD DBA Upads with any data a) which by itself identifies an individual, such as name, address, phone number, email address; and b) regarding children, or any special categories of personal data, as defined under Article 9 of the GDPR, except as may otherwise be expressly agreed in writing between the Parties and in accordance with the applicable law. This type of data is not necessary to use ADA Media LTD DBA Upads Services. Partner is responsible for ensuring their own compliance with various laws and regulations, including the GDPR. To the extent required under the applicable law, Partner shall provide an appropriate notice to Data Subjects about the Processing of their Personal Data in connection with the use of Services under this DPA and under the legal terms, and Partner shall receive and document the Data Subjects’ consent thereof to the extent required under the applicable law. To the extent required under the applicable law, Partner must also use commercially reasonable efforts to ensure that the End User is provided with clear and comprehensive information about cookies or other information on the End User’s device in connection with the use of Services by the Partner and, if applicable, consents to their storing and accessing. To the extent required under the applicable law, Partner shall inform the End User about third party cookies (or other tracking technologies) which may be placed on Partner’s site(s), specifying the purpose of these cookies (e.g., targeted advertising) and the type of data collected on the Partner’s site(s). Partner shall also inform End Users of options to deactivate ADA Media LTD DBA Upads cookies by including in its privacy policy a link to the ADA Media LTD DBA Upads legal terms and when legally compulsory, appropriate notice, consent and choice mechanisms that comply with relevant laws and regulations, including GDPR. Partner acknowledge and agree that Partner retain sole responsibility for the lawfulness of the Processing and warrant to the Upads that Partner are legally allowed to engage ADA Media LTD DBA Upads to process Personal Data on Partner behalf, have provided all necessary notices and obtained all required consents from the Data Subjects (if apply) for the purposes of the Processing described in this DPA.

RIGHTS OF DATA SUBJECTS: “ADA Media LTD DBA Upads shall notify Partner via e-mail if he receives a request from a Data Subject in the subject of access to, correction, amendment, deletion of or objection to the processing of that Data Subject’s Personal Data. ADA Media LTD DBA Upads shall not respond to any such Data Subject request without Partner’s prior written consent, except in order to confirm that the request relates to ADA Media LTD DBA Upads. To the extent that Partner responds to any such Data Subject request, ADA Media LTD DBA Upads shall provide Partner, to the extent required by law, with commercially reasonable cooperation and assistance in relation to handling of a Data Subject’s request, to the extent legally permitted. ADA Media LTD DBA Upads reserves the right to charge additional fees in relation to the cooperation with the Partner in regard to this ADA Media LTD DBA Upads shall ensure that its personnel engaged in the Processing of Personal Data is informed of the confidential nature of the Personal Data, has received appropriate training on their responsibilities and is subject to obligations of confidentiality. Such obligations shall survive the termination of that individual’s engagement with ADA Media LTD DBA Upads. ADA Media LTD DBA Upads shall ensure that access to Personal Data is limited only to those members of personnel who require that access in order to fulfil ADA Media LTD DBA Upads obligations under the Terms and Conditions.

SECURITY: Pursuant to Article 28, Section 3(c) of the General Data Protection Regulation, ADA Media LTD DBA Upads shall take the measures required by the Article 32 of the GDPR. ADA Media LTD DBA Upads shall provide sufficient guarantees of implementation of the appropriate technical and organizational measures in a manner that the processing will meet the requirements of the GDPR and ensure the protection of the rights of the Data Subject. ADA Media LTD DBA Upads imposes appropriate contractual obligations upon its personnel that engages in the Processing of Personal Data, including relevant obligations regarding confidentiality, data protection and data security. ADA Media LTD DBA Upads ensures that its applicable personnel has been properly informed of the confidential nature of the Personal Data, has received appropriate training and has executed written confidentiality agreements. ADA Media LTD DBA Upads will further ensure that such confidentiality agreements will survive the termination of employment or another form of engagement of its personnel.

AUDIT RIGHT To the extent that the applicable law requires Partner to be in a position to monitor the adequate Processing of Personal Data, Partner as the Partner have the right to request an audit from ADA Media LTD DBA Upads to the extent necessary to review whether ADA Media LTD DBA Upads and our Sub-Processors are compliant with the following regulations: (i) any provisions of the Law, (ii) the terms of this DPA, and (iii) Partner’s instructions. ADA Media LTD DBA Upads may provide Partner with a copy of its most recent third-party audits or certifications issued by an independent, third-party auditor, as applicable, or any summaries thereof to fulfil Partner audit rights. If an audit is required by law and where its requirements cannot be fulfilled by the provision of such certification, Partner may conduct, either by Partner itself or through a third party independent contractor selected by Partner at Partner expense, an on-site audit of ADA Media LTD DBA Upads Such audit may be conducted subject to the following terms: (i) the audit will be pre-scheduled in writing with ADA Media LTD DBA Upads at least 30 days in advance and will be performed once a year at most; (ii) if applicable, all of Partner personnel performing the audit, whether employed or contracted by Partner, will execute a ADA Media LTD DBA Upads s standard non-disclosure agreement prior to the initiation of the audit, and a third party auditor will in addition execute a non-competition undertaking; (iii) Partner will undertake all necessary measures to ensure and verify that the auditors do not access, disclose or compromise the confidentiality and security of Personal Data other than Partner Personal Data on ADA Media LTD DBA Upads information and network systems; (iv) Partner will take all necessary measures to prevent any damage or interference with ADA Media LTD DBA Upads or its service providers’ information and network systems; (v) Partner will bear all costs and assume responsibility and liability for the audit and for any failures or damage caused as a result thereof; and (vi) any audit activities on ADA Media LTD DBA Upads third-party service providers’ information systems will be pre-scheduled and agreed on with the applicable providers; (vii) Partner will keep the audit results in strict confidentiality, use them solely for the specific purposes of the audit under this Section 6 and the GDPR will not use the results for any other purpose, or share them with any third party, without ADA Media LTD DBA Upads s prior explicit written confirmation; (viii) If Partner are required to disclose the audit results to a competent authority, Partner will provide ADA Media LTD DBA Upads with a prior written notice, explaining the details and necessity of the disclosure, as well as provide all further necessary assistance to prevent such disclosure.

SECURITY BREACH MANAGEMENT AND NOTIFICATION If ADA Media LTD DBA Upads becomes aware of any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to any Personal Data transmitted, stored, or otherwise Processed on ADA Media LTD DBA Upads equipment or in ADA Media LTD DBA Upads facilities (“Security Breach”), ADA Media LTD DBA Upads will promptly: (i) notify the Partner of the Security Breach; (ii) investigate the Security Breach and provide Partner with all relevant information about the Security Breach; and (iii) take all commercially reasonable steps to mitigate the effects and minimize any damage resulting from the Security Breach.

SUBPROCESSING AND TRANSBORDER DATA TRANSFERS Partner authorizes ADA Media LTD DBA Upads to appoint Sub-Processors in order to provide the Services. ADA Media LTD DBA Upads may continue to use the Sub-Processors already engaged by the ADA Media LTD DBA Upads according to this DPA. ADA Media LTD DBA Upads may integrate the Partner’s services with external service providers’ platforms for the purpose of providing its Services, on Partner’s behalf and for the purposes of serving the Partner’s interests, where such external service providers may be Sub-Processors, which Partner hereby agrees to. A full list of such Sub-Processors is available upon the Partner’s written request directed to ADA Media LTD DBA Upads. Notwithstanding the provisions above, Partner hereby authorize ADA Media LTD DBA Upads to subcontract the Processing to the Sub-Processors based outside of the European Economic Area (EEA) to the extent necessary to duly perform the Service(s), under the condition that the Sub-Processors will provide sufficient guarantees in relation to the required level of data protection, e.g. through a Privacy Shield certification according to the EU Commission Decision 2016/1250, or a subcontracting agreement based on the standard contractual clauses launched by virtue of the EU Commission Decision on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC or GDPR (the “Model Contract Clauses”), or based on other applicable transborder data transfer mechanisms.

OTHERS Term: This Agreement shall become effective as of May 25, 2018. Partner authorizes ADA Media LTD DBA Upads to retain Personal Data for a period of 3 months from the date of its collection on Partner’s behalf and for the purpose of serving its interests, including for fraud prevention, ad security services, reporting services, complaints or chargebacks handling. This data may be deleted from ADA Media LTD DBA Upads servers after this retention period and/or after the termination of Agreement or earlier, at Partner written request. Notices: If Partner wish to make any inquiries about this Agreement, please contact Liability: Partner shall indemnify and hold ADA Media LTD DBA Upads its officers, directors, employees, contractors, and agents harmless from and against all claims, liabilities, administrative fines, suits, judgments, actions, investigations, settlements, penalties, fines, damages and losses, demands, costs, expenses, and fees including reasonable attorneys’ fees and expenses, arising out of or in connection with any claims, demands, investigations, proceedings, or actions brought by data subjects, legal persons (e.g., corporations and organizations), or supervisory authorities under the data protection laws that apply to ADA Media LTD DBA Upads in respect of processing of Personal Data on behalf of Partner through Services. The liability of each party under this Agreement shall be subject to the exclusions and limitations of liability set out in the legal terms. Governing law: This Agreement shall be governed by, and is construed in accordance with, the laws of the State of Spain, without giving any effect to any choice of law and provisions thereof that would cause the application of the laws of any other authority.