Privacy Policy

01 Who we are

BENEVIA PTE. LTD. ("BENEVIA", "we", "us" or "our") is a company incorporated in the Republic of Singapore under Unique Entity Number 202611046C, with its registered office at 152 Beach Road, #23-02, Gateway East, Singapore 189721.

We operate an advertising technology platform that allows advertisers to deliver advertisements across third-party websites and mobile applications, and that measures how those advertisements perform. To do that, we collect data about the businesses that use our platform, about the people who represent those businesses, and about the people who visit or use the digital properties where our technology is present.

What this policy covers

This policy applies to our advertising platform, to our own website at benevia-ad.com, and to all related products and services. Sections 14 to 17 set out additional terms that apply depending on where you are located; where those sections conflict with the rest of this policy, they prevail for people in the jurisdiction concerned.

02 Definitions

03 Data we collect

3.1 About Users

To select, deliver and measure advertisements, we collect the following through cookies, software development kits, pixels and comparable technologies present on Client properties:

• Identifiers — cookie identifiers, session identifiers, mobile advertising identifiers and comparable pseudonymous references used to deliver advertisements, cap how often you see them, and attribute their effects.
• Approximate location — the general area inferred from your IP address. We do not collect precise satellite location from the web.
• Activity on Client properties — pages opened, search terms entered, time spent, items viewed or purchased, prices, product categories, quantities, transaction currencies, and product or order references.
• Traffic patterns — the source that referred you, where you go next, how often you return, whether the same identifier appears on more than one device, and the general sequence of your browsing.
• Device characteristics — device type and model, operating system, screen dimensions, browser type and version, and language settings.
• Advertising interactions — which advertisements were rendered to you, whether they were viewed or clicked, and any visit or purchase that followed.
• Inferences — likely interests and preferences derived from the above, used to decide which advertisements are relevant.

3.2 About Clients and Authorised Users

• Business contact details — name, business email address, organisation, job title, country or region, and the content of messages you send us.
• Account and campaign data — login credentials, profile and dashboard settings, creative assets, placement specifications, budgets, billing addresses, payment records and transaction history.
• Technical data — IP address, browser and operating system, timestamps, device identifiers, pages opened, links followed and approximate location, collected automatically when you use the platform.

3.3 About Site Visitors

When you visit benevia-ad.com, our hosting provider records standard server log information: IP address and the approximate country inferred from it, browser and operating system, the pages requested, the referring page, and the date and time of the request.

If you write to us through the enquiry form on that website, we receive your name, your email address and your message, which are required in order for us to reply, together with your company name, telephone number and the service you selected as being of interest, which are optional. We use these details to respond to you and, if the enquiry leads to one, to manage the resulting engagement. The form is operated by Formspree — see section 5 — and you may email us directly at info@benevia-ad.com instead if you prefer.

3.4 From other sources

We may also receive personal data from a Client's organisation, from advertising partners and exchanges, from service providers such as payment processors, and from publicly available sources and licensed data providers.

3.5 What we do not collect

We do not knowingly collect or use special or sensitive categories of data — such as data revealing health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sexual life or criminal records — for advertising targeting, and our contracts require Clients not to transmit such data to us.

04 How we use it

• Operating the Services — selecting and delivering advertisements, verifying delivery, capping frequency, attributing outcomes, producing reports and analytics, administering accounts and providing support.
• Measurement and optimisation — assessing which placements, audiences and creatives perform, and improving our bidding and targeting logic.
• Billing and administration — invoicing, processing payments, maintaining records and managing contracts.
• Communicating with you — answering enquiries, sending service and account notices, and handling complaints.
• Marketing our own services — telling Clients and prospective Clients about our products and features, where permitted by law and subject to the opt-out in section 7.
• Security and integrity — detecting and preventing fraud, invalid traffic, bot activity and other abuse, and enforcing our terms.
• Legal compliance — meeting our obligations and responding to lawful requests from courts, regulators and public authorities.
• Any other purpose notified to you at or before the point of collection, or to which you have consented.

05 Who we share it with

• Companies in our group, for shared infrastructure, administration and coordination.
• Clients and advertising partners — including advertising exchanges, supply-side platforms, other demand-side platforms and measurement providers, to the extent necessary to select, deliver and measure campaigns.
• Service providers acting on our behalf, under contract and on our instructions — including Formspree, Inc. (United States), which receives and forwards enquiries submitted through the form on this website, together with our hosting and cloud infrastructure providers, analytics providers, payment processors and professional advisers.
• Parties to a corporate transaction — a prospective purchaser, investor or successor in a merger, acquisition, reorganisation, financing or insolvency, subject to appropriate confidentiality protections.
• Courts, regulators and authorities, where required or permitted by law, or where necessary to establish, exercise or defend legal claims or to protect the rights or safety of any person.

We may also share information that has been aggregated or de-identified so that it can no longer reasonably be used to identify an individual.

06 Cookies and similar technologies

6.1 On our own website

benevia-ad.com does not set cookies. We run no analytics, advertising or tracking scripts on it, and we do not build profiles of the people who visit it. The typefaces and icons used on the site are served from our own servers, so loading this page does not cause your browser to contact any third-party content delivery network and does not disclose your IP address to one. Apart from the standard server log described in section 3.3, and any enquiry you choose to send us, we collect nothing from visitors to this website.

6.2 On Client properties

Our advertising technology operates on websites and applications run by our Clients. There we and our partners use cookies, pixels, web beacons, embedded scripts, software development kits and server logging to recognise a browser or device, select advertisements, limit repetition, and measure results. The categories are:

6.3 Your choices

The choices available to you depend on where you are.

In the United States, the applicable laws give you the right to opt out of the sale and sharing of your personal information rather than requiring your consent before advertising technologies are used. You can exercise that right at any time, and we do not require you to give a reason or create an account:

• through our Do Not Sell or Share My Personal Information page, linked from the footer of every page on this website;
• by sending a Global Privacy Control signal from your browser, which we treat as a valid opt-out; or
• through any of the browser, device and industry controls described in section 7.

In Japan, identifiers such as cookie IDs are personal related information (個人関連情報) rather than personal data in our hands. Where we provide them to a third party in circumstances where that third party will treat them as personal data, the Act requires that your consent has been obtained. Section 15 explains how this works and what you may ask us for.

Elsewhere, and wherever the operator of a property you visit presents its own notice or choice screen, that operator decides what it asks you and records your answer. The browser, device and industry controls in section 7 are available to you regardless of where you are.

6.4 Identifying the technologies we use

The categories in the table above describe what we place and why. If you would like the specific details for a particular property — the names of the technologies set, the domain they are set on and how long each lasts — write to info@benevia-ad.com and we will provide them. You can also inspect them at any time through the storage or cookie panel of your browser's developer tools.

07 Advertising choices

Opting out of interest-based advertising does not stop you seeing advertisements. It means the advertisements shown to you should not be selected on the basis of your activity, and may instead be selected on the basis of the page you are viewing.

• Browser settings — most browsers let you be notified before a cookie is set, delete existing cookies, or refuse them. Settings apply per browser and per device, so you would need to repeat this everywhere you browse.
• Mobile devices — iOS and Android both provide a setting to limit ad tracking or reset your advertising identifier.
• Industry programmes — the Digital Advertising Alliance, the Network Advertising Initiative and, for mobile applications, AppChoices operate opt-out tools covering participating companies. We are not responsible for the operation or accuracy of programmes we do not run.

Third parties may continue to use cookies for analytics, fraud prevention and other purposes that an interest-based advertising opt-out does not cover.

Marketing emails we send to business contacts each contain an unsubscribe link. You may also opt out by writing to us. This does not affect operational messages about an existing account.

08 How long we keep it

We keep personal data only for as long as it is needed for the purpose it was collected for, or for as long as we are required or permitted to keep it by law. In setting periods we consider the sensitivity of the data, the risk of unauthorised use, whether the purpose can be met another way, and our legal, tax and accounting obligations.

When a period ends we delete, destroy or irreversibly anonymise the data, or isolate it securely until deletion becomes technically feasible.

09 Security

We maintain technical and organisational measures appropriate to the risk presented by the personal data we handle, and we keep those measures under review. If you are a client or a prospective client and need to assess our security arrangements in detail, write to info@benevia-ad.com and we will respond to a security questionnaire or due diligence request.

No system can be guaranteed completely secure. We will never contact you to ask for your password or other account credentials.

10 International transfers

We are established in Singapore and operate infrastructure, personnel and partners across several countries. Personal data may therefore be transferred to, stored in, or accessed from Singapore, the United States, Japan and other jurisdictions in which our group companies, service providers and advertising partners operate.

Where we transfer personal data across borders we take steps to ensure it continues to receive a comparable standard of protection. Depending on the transfer we rely on one or more of the following:

• legally enforceable contractual obligations requiring the recipient to protect the personal data to a standard comparable to the PDPA, including where appropriate the ASEAN Model Contractual Clauses;
• transfer to a recipient holding a valid APEC Cross Border Privacy Rules or Privacy Recognition for Processors certification;
• transfer to a jurisdiction recognised as providing a comparable level of protection; or
• another mechanism permitted under the applicable law, including the Personal Data Protection Regulations 2021 of Singapore and, for personal information originating in Japan, Article 28 of the Act described in section 15.

You may ask us for details of the safeguards applying to a particular transfer; we may redact commercially sensitive information.

11 Third-party services

Our Services operate on, and may link to, websites and applications controlled by others. Those properties are governed by their own privacy notices and we are not responsible for them. We encourage you to read the relevant notice before providing information.

12 Children

Our Services are directed at businesses. They are not intended for, or marketed to, children, and we do not knowingly collect personal data from anyone under the age of 16 or deliver interest-based advertising to them. If you believe a child has provided personal data to us, please contact us so that we can delete it. Jurisdiction-specific age thresholds are noted in sections 14 to 16.

13 Your rights

Depending on where you are located, you may have the right to ask us for access to the personal data we hold about you, to correct or delete it, to restrict or object to how we use it, to receive it in a portable format, and to withdraw consent. Sections 14 to 16 set out the position in specific jurisdictions.

To exercise a right, email info@benevia-ad.com, telling us which right you are exercising and giving enough detail for us to identify you and locate the relevant data. Because much of the data we hold about Users is pseudonymous, we may need you to supply the relevant identifier — for example by using the opt-out tools in section 7 — before we can act. We may also need to verify your identity. If we cannot identify you from the data we hold, we will tell you so.

Where personal data was collected on a Client's property and that Client determines how it is used, we will refer you to that Client and assist them in responding.

14 Singapore (PDPA)

This section applies to individuals in Singapore and is given under the Personal Data Protection Act 2012 (Act 26 of 2012), together with its subsidiary legislation and the guidelines and codes of practice issued by the Personal Data Protection Commission (the "PDPA").

Data Protection Officer

We have appointed a Data Protection Officer under section 11(3) of the PDPA, who is responsible for ensuring our compliance with it. You may contact the DPO about any matter relating to your personal data:

Please give your full name, a clear description of your request and any context that helps us locate the relevant data. We may need to verify your identity before acting. We aim to acknowledge your message within 1–2 business days and to respond substantively as soon as practicable, and in any event within the period prescribed by the PDPA.

Consent

We collect, use and disclose personal data on the basis of consent, including deemed consent, unless an exception applies. In some circumstances we rely on the legitimate interests exception, the business improvement exception, or another exception in the First or Second Schedule to the PDPA. You may withdraw consent at any time by contacting our DPO; we will tell you the likely consequences and stop the relevant handling within a reasonable period unless required or permitted to continue.

Our role

We are the organisation responsible under the PDPA for the personal data we collect and use for our own purposes, including the identifiers and advertising interaction data described in section 3. Where we instead handle personal data on a Client's behalf, that Client remains the responsible organisation and we comply with the protection obligation (section 24 of the PDPA) and the retention limitation obligation (section 25 of the PDPA) in respect of that data.

Your rights

Subject to the conditions and exceptions in the PDPA, you may request access to the personal data we hold about you and information about how it has been used or disclosed in the preceding year; correction of an error or omission; withdrawal of consent; and, to the extent the portability provisions are in force and applicable, transmission of your data to another organisation. A reasonable fee may apply to an access request and we will tell you the amount in advance.

Accuracy, transfers and Do Not Call

We take reasonable steps to keep personal data accurate and complete where it is likely to be used in a decision affecting you or disclosed to another organisation (section 23 of the PDPA). Transfers outside Singapore are made in accordance with section 26 of the PDPA and are described in section 10 of this policy above. Before sending specified marketing messages to a Singapore telephone number we will either check the relevant Do Not Call Registers or rely on clear and unambiguous consent.

Data breaches and complaints

Where a breach results or is likely to result in significant harm, or affects or is likely to affect 500 or more individuals, we will notify the Personal Data Protection Commission as soon as practicable and no later than three calendar days after assessing it as notifiable, and will notify affected individuals where required. Please raise any concern with our DPO first; if you remain dissatisfied you may complain to the Personal Data Protection Commission (+65 6377 3131).

15 Japan (APPI)

This section applies where we handle personal information governed by the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003, as amended).

We use personal information for the purposes set out in section 4 and will not exceed the scope necessary to achieve them without consent, except where the Act permits. We do not provide personal information to third parties without consent except where the Act permits, including where the recipient is a contractor handling data on our behalf within the scope of the entrusted purpose.

Personal related information

Cross-border transfers

Personal information we handle is transferred to and stored in Singapore and the other jurisdictions described in section 10. Before making such a transfer we provide information about the receiving country, its data protection framework and the measures taken by the recipient and obtain consent, or rely on a permitted alternative under Article 28 supported by contractual measures and periodic verification.

Your rights

You may request disclosure of the personal information we hold about you, including records of provision to third parties; correction, addition or deletion of inaccurate information; and cessation of use or provision. Please write to info@benevia-ad.com. You may also contact the Personal Information Protection Commission.

16 United States

This section supplements this policy for residents of United States states that have enacted comprehensive consumer privacy laws. As at the effective date of this policy those states are California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia. Further states have enacted laws that are not yet in force, and this section is intended to apply to them as they take effect. The rights described below are those available under the law of your own state; not every right is available in every state. This section does not apply to publicly available, de-identified or aggregated information.

Categories collected in the preceding 12 months

From Clients and their representatives: identifiers (name, business email address, username); customer records (login credentials); commercial information (services purchased or considered, transaction history); approximate geolocation from IP address; professional information (job title, employer); the content of messages you send us; and inferences about interests and preferences.

From Users and Site Visitors: internet and network activity (device information, logs, advertising interactions); approximate geolocation from IP address; and inferences about interests and preferences.

Sources, purposes and recipients are those set out in sections 3, 4 and 5.

Sale and sharing

In the preceding 12 months we disclosed internet and network activity information and approximate geolocation to analytics providers, advertising networks and exchanges, and advertising partners, in ways that may constitute a "sale" or "sharing for cross-context behavioural advertising" under applicable state law. We do not knowingly sell or share the personal information of consumers under 16 without opt-in consent from the consumer (aged 13 to 15) or from a parent or guardian (under 13).

We treat account credentials combined with a password or security code as sensitive personal information. We use it only for expected service purposes, security and fraud purposes and short-term transient use, and we do not sell it or use it for targeted advertising. Where we hold de-identified information we maintain it in that form and do not attempt to re-identify it, except as permitted or required by law.

Your rights

Subject to state law, you may request to know the categories and specific pieces of personal information we have collected, their sources, our purposes and the categories of recipients; request deletion; request correction; opt out of sale or sharing for targeted advertising; and opt out of profiling used in decisions producing legal or similarly significant effects. Access requests are limited to twice in a 12-month period. We will not discriminate against you for exercising these rights.

How to exercise them

• Requests — email info@benevia-ad.com with "Privacy Request" in the subject line.
• Opt out of sale or sharing — use the Do Not Sell or Share My Personal Information page, linked from the footer of every page on this website, or the tools described in section 7.
• Global Privacy Control — we treat a GPC browser signal as a valid opt-out of sale and sharing. If your browser sends one, it is applied automatically and you do not need to take any further step.
• Authorised agents — an agent may act for you on production of a valid written authorisation or power of attorney, and we may still verify your identity directly.

Appeals

If we decline your request you may appeal by emailing us with "Privacy Request Appeal" in the subject line, identifying the original request and your grounds. We will respond in writing within 60 days, or such other period as state law requires. If you remain dissatisfied you may complain to the Attorney General of your state.

California "Shine the Light"

If you are a California resident with an established business relationship with us, you may request once per calendar year, free of charge, a list of the categories of personal information we disclosed to third parties for their own direct marketing purposes during the preceding calendar year, and the names and addresses of those third parties (Civil Code § 1798.83). Email us with "California Shine the Light Request" in the subject line; we will respond within 30 days of a verified request.

Nevada

Nevada residents may direct us not to sell certain covered information under Nevada Revised Statutes Chapter 603A by emailing info@benevia-ad.com.

17 Changes to this policy

We may revise this policy from time to time. The effective date at the top of this page shows when it was last changed, and the current version is always available at benevia-ad.com/privacy.html. Where a change is material we will give more prominent notice, which may include emailing the contacts we hold or a notice within the Services.

18 Contact us

For any question, request or complaint about this policy or about how we handle personal data:

We aim to acknowledge your message within 1–2 business days.