1. Introduction & Operating Entity
This Data Use and Privacy Statement ("Statement") describes how DKDEV, LLC ("Company," "we," "us," or "our"), a Texas limited liability company operating AdEye NZ, collects, manages, safeguards, and processes information through the AdEye NZ political advertising intelligence platform, dashboards, data feeds, and associated web properties at adeye.nz (collectively, the "Service").
This Statement applies to all prospective and registered users, organization administrators, authorized seat holders, and visitors to our website, in compliance with the New Zealand Privacy Act 2020 (including the Information Privacy Principles), the General Data Protection Regulation (GDPR) where applicable, and applicable privacy statutes.
2. Categorical Prohibition on Data Sale & External Sharing
DKDEV, LLC maintains a zero-tolerance policy against data monetization:
- No Sale of Personal Data: We have never sold, rented, or licensed personal information or customer metadata to any third party, and we will never do so in the future.
- No Cross-Context Behavioral Advertising: We do not track users across non-affiliated websites, and we do not permit third-party advertising tracking networks, tracking pixels (such as the Meta Pixel or Google Ad tags), or retargeting scripts on the authenticated AdEye platform.
- No Data Sharing Outside AdEye: Your account information, internal queries, district selections, notes, and viewing history remain strictly confidential within your provisioned organization and our secure technical perimeter.
3. Information We Collect
We collect only the minimum information necessary to provision seats, secure access, and process billing:
A. Account & Provisioning Data
When you register an account, we collect your organization name, work email address, hashed authentication credentials, and terms acceptance timestamp. Password credentials are cryptographically hashed using industry-standard salt and hash algorithms; plaintext passwords are never stored or accessible by DKDEV personnel.
B. Billing & Payment Records
All payment processing is executed directly by our third-party payment processor, Stripe, Inc., a PCI-DSS Level 1 certified provider. We collect subscription status, tier choices, and state footprint selections. We never store, process, or have access to raw credit card numbers or banking account credentials. Payments appear on billing statements under the descriptor "DKDEV" or "DKDEV LLC / ADEYE".
C. Operational & Security Telemetry
To enforce Section 4 (Named Seat Licensing) and Section 5 (Scraping Prohibition) of our Terms of Service, we record timestamps, client IP addresses, session tokens, and browser user-agent strings. This telemetry is utilized solely to detect abusive credential sharing, mitigate denial-of-service attempts, and protect infrastructure integrity.
D. Customer-Authorized Platform Integrations (Optional)
If an authorized campaign administrator voluntarily chooses to connect authorized advertising accounts (e.g. Meta Business Manager, Google Ads, Snapchat, Roku) through our consent portal for early ad monitoring, we store OAuth tokens strictly to retrieve the authorized campaign ads pursuant to your selected timing rules. You retain full unilateral power to revoke access at any time, which automatically purges stored tokens.
4. Distinction: Public Source Data vs. Personal User Data
AdEye NZ functions primarily as an analytics search engine and aggregator for Public Source Data. Public Source Data consists of broadcast television political advertising filings, radio disclosure files, digital ad library listings (Meta, Google, Snapchat), and official election transparency disclosures from the New Zealand Electoral Commission (Te Kaitiaki Take Kōwhiri) and Broadcasting Standards Authority (BSA).
Public Source Data is matter of official public record and does not constitute private personal data of AdEye NZ users. Our processing of public campaign filings is governed by public disclosure laws, press freedoms, and transparency statutes, and is entirely segregated from user account information.
5. Purposes and Legal Bases for Processing (GDPR Article 6)
We process personal data only when an established lawful basis applies under GDPR Art. 6 and applicable law:
- Performance of Contract (Art. 6(1)(b)): To authenticate authorized seats, provision access to state feeds, process monthly subscription billing via Stripe, and communicate essential service notices.
- Legitimate Interests (Art. 6(1)(f)): To safeguard platform infrastructure, enforce named seat restrictions, prevent unauthorized automated scraping, investigate fraudulent activity, and maintain operational stability.
- Legal Obligation (Art. 6(1)(c) / Privacy Act 2020): To comply with applicable statutory accounting, tax, campaign disclosure, and corporate governance record-keeping duties under New Zealand and applicable law.
- Consent (Art. 6(1)(a)): For optional campaign-side connected account data sharing or optional performance telemetry. Consent may be withdrawn at any time.
6. Authorized Technical Service Providers (Data Processors)
To provide a resilient, high-speed cloud platform, DKDEV, LLC engages a small group of vetted technical infrastructure providers. Each provider acts strictly as a data processor under binding Data Processing Addenda (DPAs) that restrict processing solely to our explicit instructions:
Payment gateway, PCI-DSS recurring subscription billing.
Encrypted PostgreSQL cloud database hosting & authentication.
Transactional email delivery (verification links & alerts).
We do not transfer your personal information to any other entities unless compelled by a binding subpoena or court order issued by a court of competent jurisdiction in New Zealand or the United States.
7. Data Retention & Cryptographic Security
We employ comprehensive technical and organizational safeguards engineered to protect personal data against accidental loss, unauthorized access, alteration, or disclosure:
- Encryption in Transit: All data transmitted between your browser and our servers is secured with TLS 1.3 encryption.
- Encryption at Rest: Database backups and persistent volumes are encrypted using AES-256.
- Access Control: Administrative access is restricted to verified engineers via hardware multi-factor authentication and HMAC-signed session tokens.
- Retention Schedule: Account data is retained for the duration of your active subscription and deleted within 90 days following account closure, except where required by statutory tax and corporate accounting retention rules (typically 7 years for financial ledger records).
8. Your Statutory Rights (New Zealand Privacy Act 2020 & GDPR)
Depending on your geographic location and jurisdiction, you possess specific legal rights regarding your personal information:
Right of Access (Principle 6 / GDPR)
You have the right to request confirmation of whether we hold personal information about you and to obtain a copy of that data.
Right to Request Correction (Principle 7 / GDPR)
You have the right to request correction of inaccurate, out-of-date, or incomplete personal details stored in your profile.
Right to Erasure ("Right to be Forgotten")
You may request complete deletion of your personal account records, subject to statutory legal and financial retention requirements.
Right to Non-Discrimination
We will never deny you service, charge differing prices, or provide degraded service for exercising your privacy rights.
To exercise any statutory right, submit a verifiable consumer request to privacy@adeye.nz. We respond to all verified requests within statutory timeframes without charge.
9. Cookies, Local Storage & Consent Management
AdEye maintains a clean, privacy-first technical footprint:
- Strictly Necessary Cookies: Essential session cookies used to authenticate your account (Supabase tokens) and admin access. These cannot be disabled as they are required for basic site security and operation.
- Functional Local Storage: Client-side storage of theme preferences (dark/light mode) and consent preferences.
- No Advertising Cookies: We do not use third-party marketing cookies, profiling algorithms, or tracker scripts.
You can review or adjust your consent choices at any time via the "Cookie Preferences" control located in the footer of every page.
10. Campaign Finance & Anti-Coordination Confidentiality
In alignment with Section 6 of our Terms of Service, AdEye operates with strict organizational boundaries. An organization's internal queries, watchlists, saved views, and seat allocations are kept strictly segregated. We do not cross-reference or disclose one campaign's monitoring focus to any other campaign, committee, or vendor.
11. Contact Information & Data Protection Inquiries
For questions, privacy requests, or data protection inquiries, contact our legal and privacy team:
DKDEV, LLC — Data Privacy Office
Operating AdEye NZ
Privacy Inquiries: privacy@adeye.nz
General Support: support@adeye.nz