Privacy Policy
Last updated: [DATE]
Banche Labs, Inc. (“Banche Labs,” “we,” “us,” or “our”) operates the Chosen ad network (https://chosen.ad). This Privacy Policy explains how we collect, use, share, and protect information when you interact with the Chosen network as a Curator, Publisher, Advertiser, or Platform.
1. Information We Collect
From Curators (via Platforms or directly)
- Selection data: which ads you are presented with, which you select, selection timing, examination patterns (hover, dwell, click-through during selection), and notes you provide
- Published-phase engagement: impressions, clicks, and audience engagement on your scope after an ad is selected
- Scope characteristics: information about your property relevant to ad matching (content category, audience demographics if provided by your Platform, historical selection patterns)
- Identity tokens: issued by your Platform or by Chosen directly, identifying you and your scope
From Advertisers
- Account information: email address, organization name, billing details
- Ad creatives: images, text, links, and metadata you submit
- Campaign data: budget, creative variants, withdrawal and blocking actions
From Publishers
- Account information: email address, property details
- Property characteristics: content category, audience description, integration method
- Performance data: impression counts, click-through rates, audience engagement patterns
From Platforms
- Platform registration: organization name, API key, integration details
- User identity tokens: signed tokens identifying Curators and their scopes
- Scope metadata: scope characteristics relevant to ad matching
Collected Automatically
- Server logs: IP address, browser type, operating system, referring URL, timestamps. Retained for security and operational purposes.
- SDK session data: session identifiers, page context, and timing data collected by the Chosen SDK when it runs on a publisher’s property or Platform
- Cookies: a session cookie for ad selection session tracking. We do not use analytics, advertising, or third-party tracking cookies.
2. How We Use Information
| Purpose | Information used | Legal basis (GDPR) |
|---|---|---|
| Operate the ad network (curate selection sets, record selections, serve ads) | Selection data, scope characteristics, identity tokens | Performance of contract |
| Improve ad matching (learn publisher preferences, estimate creative appeal) | Selection data, published-phase engagement, scope characteristics | Legitimate interest |
| Build and maintain publisher and creative representation models (embeddings, taste profiles) | Aggregated selection and engagement patterns across publishers and creatives | Legitimate interest |
| Advertiser reporting (selection rates, impressions, publisher breakdown) | Selection data, impression data (aggregated) | Performance of contract |
| Publisher/Curator reporting (compensation, selection history) | Selection data, compensation records | Performance of contract |
| Billing and compensation | Account data, budget data, selection records | Performance of contract |
| Prevent fraud and abuse | Server logs, engagement patterns, identity tokens | Legitimate interest |
| Respond to legal requests | Account information, logs | Legal obligation |
3. Information We Share
With Platforms
When a Curator accesses Chosen through a Platform, we share selection state (which ad is currently selected for a scope) and aggregate performance data with the Platform to support their integration.
With Advertisers
Advertisers receive aggregate reporting: selection rates, impression counts, click-through rates, and publisher-level breakdowns (which publishers had access to their ad and which selected it). Advertisers do not receive individual Curator identity information beyond what is visible on the publisher’s property.
With Publishers / Curators
Publishers and Curators see their own selection history, compensation records, and scope-level performance data.
Service Providers
We use service providers for hosting, payment processing, and infrastructure. They process data on our behalf and are contractually required to protect it.
Legal Authorities
When required by law, regulation, legal process, or governmental request.
Business Transfers
In connection with a merger, acquisition, or sale of assets, information may be transferred as part of that transaction.
What We Do Not Do
- We do not sell personal information.
- We do not share individual Curator selection data with advertisers (only aggregate reporting).
- We do not share data with ad networks other than Chosen.
- We do not use data for purposes beyond operating and improving the Chosen ad network.
4. Cookies
We use one essential cookie:
| Cookie | Purpose | Type | Duration |
|---|---|---|---|
| chosen_session | Ad selection session tracking | First-party, HttpOnly | Session |
We do not use analytics, advertising, or tracking cookies. When the Chosen SDK runs on a Platform or Publisher’s property, the Platform or Publisher is responsible for disclosing this cookie in their own cookie policy.
5. Data Retention
- Selection and engagement data: retained for as long as the associated Curator, Publisher, or Advertiser account is active, and for a reasonable period afterward for aggregate analysis
- Account data: retained for as long as the account is active. Deleted upon account closure, subject to legal retention requirements.
- Server logs: retained for a standard operational period
- Aggregated and anonymized data: may be retained indefinitely
6. Your Rights
Depending on your location, you may have the following rights:
- Access: request a copy of the information we hold about you
- Correction: request that we correct inaccurate information
- Deletion: request that we delete your account and associated data
- Portability: receive your data in a structured, machine-readable format
- Objection: object to our processing where we rely on legitimate interest
- Restriction: request that we restrict processing in certain circumstances
- Withdraw consent: where processing is based on consent, you may withdraw at any time
To exercise these rights, contact us at chosen-privacy@banchelabs.com.
7. International Data Transfer
Chosen is operated from the United States. If you access the network from outside the United States, your information will be transferred to and processed in the United States and other countries where our service providers operate.
8. Children’s Privacy
The Chosen ad network is not directed at children under 13 (or 16 in jurisdictions where that is the minimum age of digital consent). We do not knowingly collect information from children under these thresholds.
9. Data Security
We implement technical, administrative, and organizational measures to protect information against unauthorized access, alteration, disclosure, or destruction. No method of transmission or storage is completely secure.
10. Changes
We may update this Privacy Policy from time to time. We will use best efforts to notify affected parties at least one month before material changes take effect.
11. Contact
If you have questions about this Privacy Policy, contact us at:
Banche Labs, Inc.
chosen-privacy@banchelabs.com