Privacy Policy

DEFINITIONS

Cookies are small files stored on your device (computer or mobile device).

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User) is any living individual who is using our Service and is the subject of Personal Data.

Personal Data means data about a living individual who can be contacted or identified from those data (or from those and other information either in our possession or likely to come into our possession).

Service is (1) the https://adsinc.com/ website operated by ADS; (2) the https://twipv.com website, operated by Theodor Wille Intertrade (TWI), a subsidiary of ADS; and (3) the https://www.4star-tech.com/ website operated by 4 Star Technologies, Inc., a subsidiary of ADS.

Usage Data is data on how the Service is accessed and used and generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

INFORMATION COLLECTION AND USE
We collect several different types of information for various purposes to provide and improve our Service to you. The following are types of data collected

INFORMATION COLLECTION AND USE
We collect several different types of information for various purpose>Personal Data: While using our Service, we may ask you to provide us with Personal Data. Such Personal Data may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

Usage Data: We may also collect Usage Data. This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data: We use cookies and similar tracking technologies (e.g., such as beacons, tags, and scripts) to ensure the basic functionalities of the website and to enhance your online experience. With these technologies, we may track your activity on our Service and we hold certain information, including Personal Information such as IP address or device identifier. For more information about the cookies we use, visit our Cookie Preferences tool.

Personal information, such as IP address or device identifier, collected from some cookies may be shared with our analytics and marketing partners. You may opt-in or opt-out of certain categories of cookies using our Cookie Preferences tool. You can also instruct your browser to refuse all cookies or to indicate when a cookie is being sent. Opting out of some categories may impact your experience on the website.

USE OF DATA
ADS uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To provide you updates and/or to advertise to you about our products and Service.
• To monitor the usage of our Service
• To detect, prevent and address technical issues

RETENTION OF DATA
ADS will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

ADS will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods. Other factors that dictate the length of retention include: the type of data; whether you have asked that you information be deleted; whether there are other legal grounds for the continued retention; whether you have objected to the retention and there are no overriding legitimate grounds for retention; and whether retention or deletion is necessary to comply with legal obligations.

TRANSFER OF DATA
Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ADS will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF DATA

Disclosure for Law Enforcement: Under certain circumstances, ADS may disclose your Personal Data.

Valid Requests by Public Authorities: ADS may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency)

Legal Requirements: ADS may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of ADS
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Other Disclosures: ADS may also disclose your personal data as follows:

• To contractors, subcontractors, vendors, and third parties who help us make our product or Service available or who support our business—for more information, see SERVICE PROVIDERS;
• To our marketing and analytics partners to improve and tailor your experience on our Service and/or to customize our advertising to your interests.
• With your consent
• To our parent company, any subsidiaries, joint ventures, or other companies under common control (collectively, “Affiliates”);
• To a company that merges with, acquires, or purchases the assets of ADS, in which case such company may continue to process your Personal Information as set forth in this Privacy Policy.

SECURITY OF DATA  

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

OUR POLICY ON “DO NOT TRACK” SIGNALS UNDER THE CALIFORNIA ONLINE PROTECTION ACT (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

GENERAL DATA PROTECTION REGULATION (GDPR)  

Legal Basis for Processing Personal Data Under the GDPR or Other Similar Laws: If you are from the European Economic Area (EEA), ADS’ legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

ADS may process your Personal Data because we need to perform a contract with you, you have given us permission to do so, the processing is in our legitimate interests and it is not overridden by your rights, and/or to comply with the law.

YOUR DATA PROTECTION RIGHTS UNDER THE GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. ADS aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where ADS, Inc. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

California Consumer Privacy Act (CCPA) – Notice at Collection

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, (collectively the “CCPA”), California residents may have certain data privacy rights, such as the right to be notified about what Personal Information categories we collect about you, and our intended use and purpose for collecting such Personal Information. This section describes the Personal Information we may have collected directly from you or indirectly about you if you use our Service or otherwise interact with ADS, and how we have used and/or disclosed your Personal Information. It also describes the Personal Information that we will collect and the purposes for that collection, as well as your rights under the CCPA.

This portion of the Privacy Policy applies to California residents who visit the website, who are ADS’ business-to business contacts or prospects, who are ADS job applicants, or who otherwise interact with ADS outside of the employment context.

Categories of Personal Information Collected: We may collect the following categories of Personal Information from or about you, with the type of information collected varying depending on interaction with ADS:

• Identifiers such as a real name, postal address, IP address, email address, account name, telephone number, and device identifier;
• Other categories of personal information, such as signature and financial information, including for example your credit or debit card related information, as well as education and employment history;
• Characteristics of protected classifications under California or federal law;
• Commercial information, including for example records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information, such as your browsing and search history, information regarding your interaction with an internet website or application, and information regarding a consumer’s interaction with an internet website, application, or advertisement;
• Geolocation data;
• Audio, electronic, visual, or similar information;
• Professional or employment-related information; and
• Education information; and
• Certain Sensitive Personal Information, such information you voluntarily provide about ethnic origin or disability status when you apply for a job. We do not sell or share this sensitive Personal Information, as those terms are defined by the CCPA, and we do not use or disclose Sensitive Personal Information for purposes other than those permitted under the CCPA.

Categories of Sources from which Personal Information Is Collected: We collect these categories of Personal Information from various sources, including (a) from you, such as when you provide information to us online or at events (b) from your interactions with the Service, (c) from social media and other information you publicly post about yourself, or (d) from our marketing or other partners.

Purposes for which Personal Information Is Collected: See the USE OF DATA section, above, which describes the business or commercial purposes for which your Personal Information may be used. Additionally, for California residents who are job applicants, we collect Personal Information to assess and process your application.

Categories of Personal Information Disclosed for a Business Purpose: We may disclose any of the categories of Personal Information that we collect for a business or commercial purpose. See the CATEGORIES OF PERSONAL INFORMATION COLLECTED section, above

Purposes for which Personal Information Is Disclosed: See the USE OF DATA, TRANSFER OF DATA section and the DISCLOSURE OF DATA section, above, which describes the business or commercial purposes for which your Personal Information may be used and disclosed.

Categories of Third Parties with whom ADS Discloses Personal Information: See the USE OF DATA, TRANSFER OF DATA, and DISCLOSURE OF DATA sections, above, which describe the third parties and service providers with whom ADS may disclose your Personal Information for a business purpose. This may apply to each category of Personal Information we disclose for a business purpose.

“Selling” and “Sharing” under the CCPA: As defined by the CCPA, we “sell” and/or “share” certain online identifiers for the purposes of online advertising and analytics. Specifically, we disclose certain online identifiers to advertising partners and analytics providers. We do not have actual knowledge of “selling” or “sharing” Personal Information of minors under 16.

You have the right to opt-out of this “selling” and “sharing.” For more information about these activities and to exercise your right to opt-out, please see our “Do Not Sell or Share My Personal Information” page. As explained on that page, you may opt-out of “selling” and/or “sharing” by taking a number of actions, including (1) setting your cookie preferences for our Services or (2) setting your preference for your browser using the Global Privacy Control (GPC). Note that GPC is a browser-level tool that ADS recognizes and treats as a request to opt-out of “selling” and “sharing.” GPC is not available on all browsers.

Retention Policy: See RETENTION OF DATA, above.

California Residents’ Rights Under the CCPA: If you are a resident of California, you have:

• The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer;
• The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions;
• The right to correct inaccurate Personal Information that a business maintains about a consumer;
• To the extent the business sells or shares Personal Information as defined by the CCPA, the right to opt-out of the sale or sharing of their Personal Information by the business;
• If the business uses or discloses sensitive Personal Information for certain reasons, the right to limit the use or disclosure of sensitive Personal Information by the business; however, ADS does not use or disclose Sensitive Personal Information in a way that would trigger this right; and
• The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

How California Residents Can Exercise Your California Rights under the CCPA: If you are a resident of California:

• To exercise your right to opt out of “selling” and “sharing,” please see our “Do Not Sell or Share My Personal Information” page.
• To exercise or to inquire about your other rights, you can send an email to adslegal@adsinc.com or contact us at our toll-free phone number 866.845.3012. Please indicate in your communication that your request is pursuant to the CCPA.

We will work to verify your request using the information you provide us in the request, and we may ask you follow-up questions. Please describe your request with sufficient detail that allows us to properly understand, evaluate, verify, and respond to it.

Note, we may deny your request in whole or in part if we cannot verify your identity. You can also designate an authorized agent to make a request on your behalf. To do so, we may require that you confirm directly to us that you have provided the authorized agent permission to submit the request, and even if you elect to use an authorized agent to make a request, we may verify your identity directly with you.

SERVICE PROVIDERS
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data to perform these tasks.

Analytics and Marketing : We may use third-party Service Providers to monitor and analyze the use of our Service and to provide online marketing.

LINKS TO OTHER SITES
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHILDREN'S PRIVACY

Our Service does not address anyone under the age of 18 (“Children”).

CHANGES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

MISCELLANEOUS
Any and all claims or disputes relating to or arising from your use of this Site or the information, content, products, services, or materials on the Site or otherwise provided by ADS through your use of the Site, or the interpretation and enforcement of this Agreement shall be governed by the laws of the Commonwealth of Virginia, as it applies to a contract executed, delivered and performed solely in Virginia, and without regard to any conflict of law provisions.

Any action or proceeding seeking to enforce any provision of, or based on any right arising out of, this Agreement shall be brought against either of the parties only in the courts of the Commonwealth of Virginia, located in the city of Virginia Beach or, if it has or can acquire jurisdiction, in the United States District Court for the Eastern District of Virginia, Norfolk Division, and you and ADS hereby consent to the exclusive jurisdiction and venue of such courts (and of the appropriate appellate courts) in any such action or proceeding and irrevocably waive any objection to such jurisdiction and venue.

Process in any action or proceeding referred to in the preceding sentence may be served anywhere in the world. Your use of the Site does not subject us to any judicial process or to the jurisdiction or venue of any courts or tribunals other than those identified above, including without limitation, those in your jurisdiction or location.

This Agreement and any sale or account terms, all of which are incorporated herein (and are available for review), constitute the entire agreement between you and us regarding your use of this Site and the materials, services, and products provided to you by ADS through your use of the Site. The failure to exercise or enforce any right or provision of this Agreement shall not operate as a waiver of such right or provision.

Contact Us

If you have questions about this Privacy Policy and ADS’s privacy practices, please contact us at: adslegal@adsinc.com.