Legal
SyncMint Privacy Policy
EdgeACR | Advertisement Recognition Technology
SyncMint BV ("we", "us", "our") develops EdgeACR, an advertisement detection technology integrated by TV manufacturers into smart television devices. This policy explains what personal data we collect when EdgeACR is operating on a device on which it has been integrated, how we use it, with whom we share it, and what rights you have.
We act as data controller for all personal data collected through EdgeACR as described in this policy and in some cases as joint controller with TV manufacturers. We are registered on the IAB Europe Global Vendor List (GVL) under TCF 2.3. This policy fulfils our obligations under GDPR Articles 13 and 14 and TCF 2.3 Policies.
1. Who We Are
Data/Joint Controller: SyncMint BV, Vijzelstraat 68, 1017 HL Amsterdam, The Netherlands
Privacy enquiries: privacy@syncmint.ai
2. What Is SyncMint EdgeACR
EdgeACR is an advertisement detection service embedded into your TV by its manufacturer. When active and with your consent, it processes your TV audio output locally on the device. When a known advertisement is detected, a small event record is sent to our servers. No audio is recorded or transmitted at any point — only the fact that an advertisement was detected.
EdgeACR is part of your TV firmware. It is not a downloadable application, and it is only present on devices where the TV manufacturer has specifically chosen to integrate it.
Please note that EdgeACR detects only when advertisements are being displayed on your TV. It does not collect or record any information about what programmes, films, sport, or other content you are watching. No raw audio ever leaves your device.
EdgeACR only operates after you have been presented with a consent notice by your TV manufacturer's privacy settings screen and have actively chosen to allow it. If you do not consent, EdgeACR does not collect or transmit any data.
3. Personal Data We Collect
When EdgeACR is operating with your consent, we collect the following categories of personal data:
- Device identifiers — a persistent device identifier and the advertising identifier assigned by your TV operating system (such as the Google Advertising ID on Android TV). These do not contain your name or contact details. The advertising identifier can be reset at any time in your TV privacy settings.
- Network identifiers — your device IP address at the time of an ad detection event, used for approximate geolocation, household-level audience matching and detecting and fixing. If use case permits, we may use location-derived attributes (city, region, country) instead of the full IP address.
- Ad exposure data — the identifier of the detected advertisement and the timestamp of its detection along with location-derived attributes, used for measurement and attribution.
- Session data — timestamps and randomly generated codes used to organise and deduplicate detection events.
- Device technical information — operating system version, device type, model, and manufacturer name, used for device classification and error diagnosis.
- Consent record — a record of your consent status, maintained to ensure your privacy choices are respected at all times.
We have no information about what you watch beyond the fact that an advertisement was detected. EdgeACR does not collect viewing history, content preferences, or any information about non-commercial content.
4. Why We Collect This Data
We process personal data only for the following purposes. We do not use your data for any purpose not listed here.
Processing under your Consent
- Operating the service (TCF Purpose 1) — storing the advertisement catalog and device identity on your TV so EdgeACR can function.
- Ad measurement (TCF Purpose 7) — reporting detected advertisement events to advertisers and agencies to verify campaign delivery and effectiveness. This is the basis for our ad measurement and data licensing service.
- Audience creation (TCF Purpose 3) — building audience segments from your ad exposure history for use by programmatic advertising platforms.
- Audience insights (TCF Purpose 9) — deriving aggregated insights from ad exposure data for licensing to agencies and broadcasters.
- Service improvement (TCF Purpose 10) — using ad exposure data to improve EdgeACR detection accuracy and performance. This processing is for internal purposes only and your data is not shared with third parties for this purpose.
Processing under Legitimate Interest
- Error detection, diagnosis and prevention (TCF Special Purpose 1) — using technical and network data to detect and diagnose errors. This processing is transmitted to our network infrastructure for error diagnosis and retained for a short diagnostic period. A Legitimate Interest Assessment (LIA) has been conducted and is available to regulators on request.
- Saving your privacy choices (TCF Special Purpose 3) — storing and acting on your consent decisions so they are remembered across sessions and device restarts. An LIA has been conducted. Our public legitimate interest statement is at: https://syncmint.ai/legitimate-interests. You have the right to object to this processing at any time under GDPR Article 21 — see Section 9.
Under TCF 2.3, Legitimate Interest may not be used for advertising or profiling purposes. All audience-building, measurement, and targeting purposes above are processed under your consent only.
5. Data Retention
Personal data collected for ad measurement and audience purposes is retained for up to 3 years. We apply the principle of storage limitation and do not retain personal data beyond the period necessary for the stated purpose.
Consent records are kept for the duration of your active consent. The consent audit log is retained for up to 3 years to meet our GDPR accountability obligations under Article 5(2).
When you withdraw consent, all personal data stored on your device by EdgeACR is deleted immediately and automatically — including all device identifiers, the advertisement catalog, and ad exposure logs. This deletion is permanent and cannot be reversed.
Please note that the TV manufacturer is responsible for obtaining your consent; this may include their ability to use the data for analytics purposes.
6. How We Share Your Data
6.1 Our Role
We act as data controller for all personal data collected through EdgeACR, determining the purposes and means of processing. In some cases, we act as a joint controller with TV manufacturers. TV manufacturers who integrate EdgeACR are responsible for presenting the consent notice to you and deploying the privacy settings screen. The legal relationship with TV manufacturers in respect of the data services enabled by EdgeACR is governed by separate commercial agreements. Any data sharing involving TV manufacturers will be subject to appropriate contractual protections and will be disclosed in an updated version of this policy when that relationship is formalised. The TV manufacturer is responsible for obtaining your consent for their ability to use the data for analytics purposes.
6.2 Third Parties We Share Data With
SSPs and programmatic advertising platforms
- What we share: Audience segment signals derived from ad exposure history, together with device identifiers (advertising ID and/or IP address) required for audience matching.
- Legal basis: Your consent
Advertisers, agencies and broadcasters
- What we share: Ad exposure data and audience insights for campaign measurement, attribution and market research.
- Legal basis: Your consent
Raw data feed clients and authorised resellers
- What we share: Event-level ad exposure records (device identifiers, timestamps, ad IDs, and IP address or location-derived attributes depending on the specific agreement). Resellers may sub-license this data to their own clients subject to contractual restrictions we impose.
- Legal basis: Your consent
Consent Management Platform provider
- What we share: Consent status data, to generate and manage the privacy consent record on your device.
- Legal basis: Our legitimate interest in saving and honouring your privacy choices
6.3 No Data Brokers or DMPs Currently
We do not currently share personal data with data brokers, data management platforms (DMPs), or data exchanges beyond those described above. If this changes, we will update this policy in advance, notify you as described in Section 13, and ensure any new sharing has a valid legal basis.
6.4 Corporate Transactions
In the event of a merger, acquisition, or sale of our business or assets, personal data we hold may be transferred to the acquiring entity. We will notify you of any such change and ensure equivalent protections apply.
6.5 Legal Disclosure
We may disclose personal data to law enforcement or regulators where required by applicable law, or to protect the rights, safety, or property of SyncMint BV or others.
7. International Transfers
Personal data collected through EdgeACR is stored in regional cloud infrastructure corresponding to the market in which it is collected. We follow data localisation principles — data collected from EU/EEA users is stored and processed within the EU where possible. Some of our service providers — including network infrastructure and data transfer providers — are based outside the EEA. Where personal data is transferred to providers outside the EEA, we ensure it is protected by Standard Contractual Clauses (SCCs) under GDPR Article 46(2)(c), or by European Commission adequacy decisions where applicable. Details are available on request from privacy@syncmint.ai.
Where EdgeACR is deployed in markets outside the EU/EEA, data from those markets is stored in the relevant region where infrastructure permits, and we comply with applicable local privacy laws in each market. If you are a user outside the EU/EEA and would like to know how your data is handled locally, contact us at privacy@syncmint.ai.
8. Your Rights
Under GDPR you have the following rights. We will respond within one calendar month. To exercise any right, contact us at privacy@syncmint.ai.
- Withdraw consent (Art. 7(3)) — Withdraw consent at any time via your TV privacy settings. Turn off the toggle in Settings › Privacy › Ad Viewing Information. Takes effect immediately and all device data is deleted automatically. Does not affect the lawfulness of prior processing.
- Access (Art. 15/ EU Data Act) — Request a copy of the personal data we hold about you and information about how we use it.
- Rectification (Art. 16) — Request correction of inaccurate or incomplete data.
- Erasure (Art. 17) — Request deletion of your data. Withdrawing consent via your TV settings triggers immediate automatic deletion of all EdgeACR data on your device. You may also request deletion of your consent history records, subject to our accountability retention obligations under Art. 5(2) GDPR.
- Restrict processing (Art. 18) — Request that we limit processing in certain circumstances.
- Data portability (Art. 20) — Request your data in a structured, machine-readable format.
- Object to legitimate interest processing (Art. 21) — Object to our SP1 (error fix) and SP3 (saving privacy choices) processing at any time. We will stop SP1 processing unless we have compelling grounds overriding your interests. For SP3, note that this processing exists to remember and act on your privacy choices — practical guidance on exercising this right is at our legitimate interest statement: https://syncmint.ai/legitimate-interests.
- Lodge a complaint — Contact your national data protection authority: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
8.1 Resetting Your Advertising ID
The advertising identifier on your TV (such as the Google Advertising ID on Android TV) can be reset at any time in your TV privacy settings. Resetting it unlinks data previously associated with it from any future data collection. Contact your TV manufacturer if you cannot locate this setting.
8.2 Before Selling or Giving Away Your TV
We recommend performing a factory reset before selling or transferring your TV. This removes all EdgeACR data from the device and resets the advertising identifier, allowing the new owner to make independent privacy choices.
9. Consent and the TCF
Consent for EdgeACR is collected through a Consent Management Platform (CMP) deployed on your TV by the TV manufacturer. The CMP presents you with a consent notice before EdgeACR begins operating. Your choices are recorded in a standardised TCF 2.3 consent string stored on your device.
EdgeACR reads your consent status from this consent string before each data collection cycle. If you have not consented, or have withdrawn consent, EdgeACR does not collect or transmit any data.
EdgeACR does not use browser cookies. It uses native TV device storage only. Our GVL entry is at: https://iabeurope.eu/vendor-list/
10. Security
We apply appropriate technical and organisational measures to protect personal data, including encryption of all data in transit, access controls on our infrastructure, and device-level isolation of EdgeACR processing. If you discover a security vulnerability, please report it to privacy@syncmint.ai.
11. Children
EdgeACR operates on household TV devices that may be used by children. It does not collect any data that directly identifies a child by name, age, or similar characteristic.
If you believe a child's data has been processed in circumstances requiring additional protection, please contact us at privacy@syncmint.ai.
12. Changes to This Policy
We may update this policy from time to time. If we make material changes to what we collect, how we use it, or who we share it with, we will notify you via an on-screen notification on your TV and update the effective date above. Where required by law, we will seek fresh consent before implementing the change.
13. Contact Us
If you have any questions or complaints regarding this policy or about SyncMint's privacy practices, please contact us at: privacy@syncmint.ai or Post: SyncMint BV, Vijzelstraat 68, 1017 HL Amsterdam, The Netherlands.
We respond to all requests within one calendar month in accordance with applicable data privacy laws.