Questo tipo di servizi consente di utilizzare i Dati dell’Utente per finalità di comunicazione commerciale. Queste comunicazioni sono mostrate su questa Applicazione sotto forma di banner e altre forme pubblicitarie, anche in relazione agli interessi dell’Utente.
Ciò non significa che tutti i Dati Personali vengano utilizzati per questa finalità. Dati e condizioni di utilizzo sono indicati di seguito.
Alcuni dei servizi di seguito indicati potrebbero utilizzare Strumenti di Tracciamento per identificare l’Utente o utilizzare la tecnica del behavioral retargeting, ossia visualizzare annunci pubblicitari personalizzati in base agli interessi e al comportamento dell’Utente, rilevati anche al di fuori di questa Applicazione. Per avere maggiori informazioni in merito, ti suggeriamo di verificare le informative privacy dei rispettivi servizi.
Generalmente i servizi di questo tipo offrono la possibilità di disattivare tale tracciamento. Oltre a qualsiasi funzione di opt-out fornita da uno qualsiasi dei servizi elencati in questo documento, l’Utente può leggere di più su come disattivare gli annunci pubblicitari basati sugli interessi nell'apposita sezione "Come disattivare la pubblicità basata sugli interessi" in questo documento.
AdNow
Privacy Policy
The purpose of this Privacy Policy (hereinafter referred as “Policy”) is to inform you as to what information may be collected by Adnow LLP (Las Suite, 5 Percy Street, Fitzrovia, London, W1T 1DG) (hereinafter referred as “the Company”, “we”, “us”, “our”) from you when you visit our Website https://adnow.com (hereinafter referred as “this Website” or “our Website”), which is an online advertising platform operating in the field of traffic sales and acquisition. By this Policy we would like to inform you how your information will be used by us, with whom such information may be shared, your choices regarding the collection, use, and distribution of such information, your ability to edit, update, correct, or delete such information and the security procedures that we have implemented to protect your privacy.
We take all necessary efforts to ensure that our processing of your personal data meets the standards of EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016.
If you do not agree to all the terms and conditions of this Policy, please do not use our Website.
Collection of Information
1) If you however decide to request any information via the contact form provided on our Website, we will ask for your name and e-mail address in order to handle your personal request or to provide the services you requested from us.
2) Our Website is an advertising agency offering a user-friendly platform for interaction between publishers and advertisers. To join our Website and using our services you shall create an account.
As a part of registration process, we may ask you to provide us with the following information, which may include your personal data:
- your name for salutation;
- e-mail address for your authorization in registration purposes, for information and notification purposes during using our Website, for technical support issues;
- phone number and skype details for communication and technical support (in some cases your phone number may be requested by our partners, who cares about payouts);
- payment details (e-wallet address, bank account etc.) if applicable.
- your language (it will help us to speak with you on one language);
- password for your account on our Website (please, select for your own safety a secret and secure password in order to ensure the confidentiality of your data; in the event that you forget your password, please use the “Forgot password” function provided on the website to create a new, secure password).
All mandatory information required in order to register is marked accordingly. All further information is provided voluntarily; this data is used for the purposes stated, or to improve our online services.
We hope that you will provide us with this information. By registering on our Website you agree with our Terms of Use and the use of your abovementioned personal information in accordance with this Privacy Policy. However, if you do not want to disclose your personal data to us, please, do not submit it. This means that we will not be able to provide you the service you have requested.
3) Providing Internet advertising services our Company may collect anonymous data of users regarding the IP address of the user’s equipment, the Internet service provider, device type, browser language in use, and his version of the operating system installed on user’s equipment, information about user’s visited sites where our advertising placed such as the URL address, the date and time of visits, the pages viewed, time spent.
We may expand the list of personal data requested from you by amending this Policy.
We may expand the list of personal data requested from you by amending this Policy.
We may expand the list of personal data requested from you by amending this Policy.
If you would like to register an account on our Website and accept our Terms of Use, than we need information about you for the following purposes:
- to fulfill your request/claim from contact form on our Website;
- to provide you an opportunity to use services of our Website, including, but not limited to creating an account, billing purposes: making payouts (if you are Publisher), receiving payments from you (if you are Advertiser), providing you with technical support, etc.;
- understand and meet your needs and preferences;
- develop new and enhance existing service and product offerings;
- monitoring and analyzing trends, statistics, usage and activities in connection with our Website;
- marketing purposes (add you to our email subscription list, send you promotional materials, our partner’s information, to implement targeted display ads, etc.); you will only receive advertising if you have given your explicit consent;
- meet legal and regulatory requirements.
If you are a user whose data was collected during provision of Internet advertising services by our Company you shall know that the usage of your personal information varies depending on the relevant campaign and customer. You will be informed thoroughly about any usage of your personal information on the relevant website or within the relevant campaign. We need your personal data only for the following purposes:
- to detect fraud including creating fraud reports to be shared with advertisers/publishers;
- to determine the performance of campaigns distributed through publisher’s inventory and network and billing purposes;
- to implement personalized or behavior-based advertising (behavioral targeting);
Non-personally identifiable information may be used to analyze trends and statistics, enhance the Website’s operation, and serve content and advertisements.
We will process your personal data legally and fairly and not use it outside the purposes of which we have informed you.
Storage of personal data
Data provided to us is stored in accordance with applicable laws, at secure locations in EU. We take reasonable steps to ensure that the personal information we collect about you remains accurate, timely, and secure. In order to avoid loss or misuse of data stored by us, we take necessary technical and organizational safety measures, which are regularly checked and updated.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure and while we strive to protect your personal information, we cannot guarantee or warrant its complete security. We shall not be responsible for losses that you or any person may suffer as a result of a breach of confidentiality in respect to your use of the Website or any information you transmit to the Website. Also, we do not assume any responsibility for the data you submit to or receive from us through the Internet or for any unauthorized access or use of that information and we cannot and do not guarantee that information communicated by you to us or sent to you by us will be received or that it will not be altered before or after its transmission to us.
We have no technical influence on third parties, which are beyond our control.
We are going to store your personal data until your request to terminate Terms of Use between us. If you do not want to use services of our Website anymore and delete your account, please, notify us in your account or by contact form.
In accordance with the recommendations of Payment Card Industry Security Standards Council, customer card details are protected using Transport Layer encryption - TLS 1.2 and application layer with algorithm AES and key length 256 bit.
The company does not store user card data, but uses a payment service provider to process this data.
Transfer of personal data
We shall not pass by any means or/ and under any circumstances your information to third parties, except for the provision of this information to such third parties, which operates on our behalf and solely for the provision of Internet advertising services. You agree that we instruct third parties to process payment transactions and to forward the provided payment requisites and billing information to them solely for this purpose. We are using certified payment service providers in order to process your payments.
Disclosure of personal data
We may disclose information that we collect about you should we have reason to believe that:
- it is necessary to identify, contact, or bring legal action against persons or entities who may be causing harm to you, us, or others;
- it is necessary because of official inquiry of governmental authorities;
- it is necessary securing compliance with law's provision or with requirements of judicial proceedings concerning us;
- we may also disclose information when we believe the law requires it.
Access or corrections to your information
You are able to rectify, update or change your personal data provided to us in your account, except e-mail address. E-mail address is a unique identifier in our system and it can not be changed. Unfortunately, if you want to use our Website with another e-mail you need to register again on our Website. If you did not register an account on our Website, but you have reasons to believe that we have your personal data, please, contact us in our contact form on Website.
In addition, you may request us to delete your personal data from our database.
You may also opt out of receiving promotional communications from us at any time by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as technical notices, support or administrative notifications or information about changes to this Policy and using services on our Website.
You also has other rights, which are provided to you by data protection law, including but not limited to: to request access and have free access to your personal data that have been provided to you and that have been subject to processing; to restrict processing of your personal data; right to revoke any consent given to the processing of personal data at any time; object to processing based on the balancing of legitimate interests; right of appeal to the competent data protection supervisory authority; to be aware of the amendments made to the terms of this Policy in an efficient manner before the implementation of new amendments or, otherwise, of the new information processing policy; to have easy access to the text of this Policy and its amendments and etc.
If you have any request, complaint or claim to us in relation to processing of your personal data by us, please, send us a message in our contact form on Website (if you have registered account on our Website, you can do it there). You message must contain:
- your designation (if applicable), for example, advertiser or publisher;
- your name and e-mail address;
- description of the facts that give rise to the request, claim or complaint and the purpose sought (update, correction or deletion, or fulfillment of duties).
We consider all requests from you within 15 days. Before answering the claim, we shall verify your identity and find your personal data in our database. If the claim or information provided is incomplete, we will request additional information for your identification, which shall be provided by you within 5 days of receipt of the claim to remedy the failures. If you fail to submit the required documentation or information within 5 days of the date of the initial claim, you shall be deemed to have waived the claim. Once your request has been received with complete information, the 15 days’ term will start again. When it is not possible to answer your request within such term, we will inform you about he reasons for the delay and of the date when your request will be dealt with, which in no case may exceed 30 days following the expiration of the first term.
If you want to delete your account, please contact us at your account. If deletion is not possible for legal reasons, access to the data in question shall instead be blocked. Please note, however, that we may be unable to continue offering some or all of the services provided on our websites requiring registration in the event that your data is deleted or blocked.
Cookies files
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site.
Most web browsers are set to accept cookies as a default. You may wish to opt out by turning off cookies (please refer to the help menu on your browser), however, please, note, that if you do so, you may not be able to use the full functionalities of this website.
There is an option to change your settings collectively for various providers under preference management on “Your Online Choices”: http://www.youronlinechoices.com/uk/your-ad-choices.
You can find more information in our Cookie Policy at https://adnow.com/cookie-policy.
Third-Party Links
The Website may contain links to web sites operated and maintained by third parties over which we have no control. Any information you provide to third party websites will be governed under the terms of each website's privacy policy and we encourage you to investigate and ask questions before disclosing any information to the operators of third party websites. We bear no responsibility or liability whatsoever for the content, actions, or policies of third party websites. The inclusion of third party websites on our Website in no way constitutes an endorsement of such websites' content, actions, or policies. Please, check third-party’s policies before you submit any personal data to these websites.
Protection of minors
Persons under 18 years are excluded from our services and from providing any personal information without the consent of their parents or guardians. We do not request personal information from children and adolescents. We do not knowingly gather or collect such data and do not disclose it to third parties. If, however, we become aware that personal data regarding a child under the age of 18 has been collected on the Website we will make reasonable efforts to delete it from our records immediately.
Modifications to Policy
This Policy may be amended from time to time. We reserves the right to change this Privacy Policy at any time. Any changes to this Policy will be effective immediately upon posting the latest version on our Website. We will inform you by e-mail about changes, which may be related to purposes of personal data processing, storage terms, personal data receipts and any other essential changes to this Policy. If you disagree with the changes in our Policy, please do not use the Website after the posting of such changes online and ask us to terminate the processing of your personal data. By using the Website following the posting of changes to this Policy, you agree to all such changes.
Questions or comments or how to contact us
If you have any questions about this Policy, please contact us at our contact form: https://adnow.com/contacts.
This Privacy Policy is effective as of May 31, 2018
vi ai
I Introduction
video intelligence AG (“vi”) is the owner of the website located at www.vi.ai (the “Website”). This policy (this “Privacy Policy”) describes the personal information we may collect from you when you access or use our Services, and how we may use that information.
By having provided your consent to these terms you allow us to process your personal data to the extent the purposes of processing have been explained to you in this policy.
For questions specifically concerning this Privacy Policy or our use of your Personal Information, cookies or similar technology, please contact us by email at legal@vi.ai. You may also write to us at the following address: vi video intelligence AG, Mühlebachstrasse 70, CH-8008 Zürich, Switzerland.
This policy is current as of 25 May 2018 and implements the changes required by the EU’s Directive 2016/679 (“GDPR”).
Personal Information.
Personal information is information that can be associated with a specific person and could be used to identify that specific person (“Personal Information”). Personal Information does not include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person (“Non-Personal Information”). We may sell Non-Personal Information to third parties from time to time.
Personal data is furthermore defined by EU Directive 2016/679 as follows:
‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Legal basis for data processing
Within the EU and for EU customers the legal basis for data processing is Article 6, sections (a), (b), and (c) of EU Directive 2016/679 (“GDPR”).
For customers outside of the EU the legal basis for data processing are our Terms & Conditions of service provisioning. The security of data for EU and non-EU customers is safeguarded by the same high standard of our ISO 27001/27018 compliant combined DPMS/ISMS.
For customers in Switzerland the legal basis for data processing is the Federal Data Protection Act.
II Types of Personal Information We May Collect.
Depending on how you interact with vi’s online services, either as a connected Publisher or as an end user, we may collect the following types of Personal Information from you when you access and use our Services:
your name, postage or billing addresses, telephone numbers and e-mail addresses;
geo-location information;
IP addresses from which our website(s) are accessed;
demographic information including your age, gender, interests and favorites;
your posts on our Website and your correspondence with us; and
additional information we are required by applicable law to collect.
This data is used for the following purposes:
User Type PII Process and Purpose Description
End User IP Addresses We may use IP addresses to analyze trends, administer the Services, track your movement, and gather broad demographic information for aggregate use.
We also use the user’s IP Address in order to be able to verify that our services respect the Brand Safety standards and Fraud Detection procedures.
End User Geo-Location Information Used to determine from where customers and partners use or services. Geo-location is used in aggregated per-country form. No exact geo-location is sought or used.
Connected Publisher your name, postage or billing addresses, telephone numbers and e-mail addresses; Used for billing and correspondence purposes
Connected Publisher demographic information including your age, gender, interests and favorites; Used for general demographic purposes to fine-tune our offering and to fine-tune relevant advertising.
Connected Publisher your posts on our Website and your correspondence with us Used for correspondence purposes and to react to your demands and interests.
Connected Publisher additional information we are required by applicable law to collect. Used strictly within the legal requirements that information is sought for.
III How We Use Personal Information.
You agree that we may use your Personal Information to:
provide you use of and access to our Services;
operate, improve, and personalize our Services;
give you access to your account information;
provide you with customer service or customer support;
contact you to resolve disputes, collect fees, and troubleshoot problems with your account or our Services and for other purposes authorized by law and consistent with this Privacy Policy;
customize our advertising and marketing communications with you;
customize, measure, and improve our content and advertising based on your ad customization preferences;
deliver targeted marketing, service updates, and promotional offers based on your communication preferences;
prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities; and
enforce our Terms of Use or other applicable policies.
We retain your Personal Information as long as it is necessary and relevant for our operations. In addition, we retain Personal Information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use and take other actions permitted by law. When it is no longer necessary for us to retain your Personal Information, we dispose of it in a secure manner.
IV Your Rights
(1) You have the right to be informed on how we use your data:
This information is provided in section II and III of this Privacy Policy. Should you have any further questions, please, do not hesitate to get in contact with us (cf. above, section I, for contact details).
(2) You have the right to know who your counterpart is:
Video Intelligence AG, Mühlestraße 70, 8008 Zürich, Switzerland
(3) You have the right to know for how long we store your data
Generally, we will store your data for as long as it is operationally necessary. Your data will be deleted once you terminate your business relationship with us and no obstacle for deletion, such as a legal requirement, interferes. All our data is reviewed for usefulness every 5 (five) years.
(4) You have the right to complain to a data protection authority:
If you are an EU citizen or an EU resident please complain to the data protection authority of your home country. Please try to get in contact with us first, we will always try to seek amicable dispute resolution.
Please note that, if you are not an EU citizen or EU resident, none of these rights apply to you. Your data, however, will be held to the same secure technical standard.
(5) You have the right to ask us about what data we store:
In order to make use of this right, please get in contact with us as stated in section I.
(6) You have the right of correction:
You can request changes to the Personal Information we keep on you by sending a request to legal@vi.ai or to vi video intelligence AG, Mühlebachstrasse 70, CH-8008 Zürich, Switzerland. We will respond to your request upon verification of your identity within a reasonable period of time, and to the maximum extent practical.
(7) You have the right of deletion:
You have the right that we delete all your data, once its usefulness is no longer there or it is no longer needed for fraud prevention or other legitimate purposes.
(8) You have the right of restriction of processing:
If you want to make use of this right, please, get in contact with us, as making use of this right poses some particular challenges that need to be discussed with you on a case-by-case basis.
(9) You have the right of data transferability:
You have the right to receive your basic data in an electronic format for transfer to another provider.
(10) You have the right to withdraw consent:
If you wish to withdraw consent please get in contact with us to ensure that you are properly aware of the ramifications of a withdrawal of consent.
V Sharing Information with Others.
You agree that we may share your Personal Information with third parties as necessary to:
provide you with the Services which you elect to use, including the processing of payment for such Services;
enforce the terms and conditions of the Terms of Use made available on the Website;
comply with laws and regulations or respond to litigation;
allow for a change of ownership of vi (including, but not limited to, an acquisition by or merger with another company) and related transfer of all Personal Information to the new owner, in which case any information provided prior to such change remains protected in accordance with this Privacy Policy;
allow advertising audits and analysis;
allow us to engage a third party to perform surveys measuring your experiences and use of our Services; or
allow designated third parties to assist with transactions, disputes and other matters regarding your use of the Services.
You can find a full list of the entities that your information might be shared with here [https://www.vi.ai/legals/]. Please note that the provisioning of contextual videos leads to automatic decisions made by the auctioning system and that it is not possible in advance to determine which particular entity your data will be shared with. Please also note that only data relevant for the selection of an appropriate video will be shared and that all other data will not be affected.
VI Feedback and Posted Information.
Certain features of the Services may enable you to submit communications, suggestions, ideas, comments, questions, or other information to us (collectively, “Feedback”) as well as post information to the Website for review by all users of the Services (“Posted Information”). Feedback and Posted Information become public information and are submitted at your discretion. When you submit Feedback and Posted Information, you expressly consent to our collection, use and disclosure of such information in any manner.
VII Do Not Track Disclosures.
We may track users over time and across third-party websites to provide targeted advertising, and we do not respond to Do Not Track (DNT) signals. We may also work with third parties that use tracking technologies on our Services to collect information about your online activities over time and across different websites when you use our Services.
VIII Data and Information Security
We take a number of steps to keep your Personal Information secure from unauthorized access. For example, we ask you to use a unique and strong password and not to share this information with anyone. In addition, we use a reasonable level of encryption to limit access to the systems that store your Personal Information. Further, we respect and comply with applicable legislation on data protection.
vi.ai operates an ISO 27001/27018 compliant data protection management system as well as an information security management system comprising a total of 231 measures to safeguard your data.
IX Links.
We may display links to third-party websites. Please note that we cannot control and cannot be held responsible for the privacy policies of such websites. You should always read the privacy policy of a website to find out more about how Personal Information is collected and processed.
X Cookies.
We may also store information about you using cookies (files which are sent by us to your computer or other access device) that we can access when you visit or use the Services in the future. We collect information about the pages you view, the links you click, and other actions you take using our Services, or within our advertising or e-mail content. We do this to help improve the user experience of the Services. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the Services.
XI Social Media Sites.
We may allow you to share information with third-party social media sites, or use social media sites or other sites to create or connect to your account. Those social media sites may give us access to certain Personal Information stored by them (e.g., content viewed and information about the advertisements within the content you have been shown or may have clicked on, etc.) from your interaction with the online services. You control the Personal Information you allow us to have access to through the privacy settings on that third-party website and the permissions you give us when you grant us access. By associating an account managed by a third party with your vi account and authorizing vi to have access to this information, you agree that vi may collect, use and store the information provided by these sites in accordance with this Privacy Policy.
XII IP Addresses
Every computer connected to the Internet is given a domain name and a set of numbers that serve as that computer’s “Internet Protocol” or IP address. When you request a page from any page within the Website, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Website. We may use IP addresses to analyze trends, administer the Services, track your movement, and gather broad demographic information for aggregate use.
XIII Changes to This Privacy Policy.
We reserve the right to make changes to this Privacy Policy but acknowledge that any substantial change will require renewed consent for those parts that require your consent.
This Privacy Policy was updated on: 27 August 2018
Propeller Ads
Propeller Ads (referred to as “Propeller Ads” or “we” or “us” or “our”) is committed to protecting and respecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process may vary depending on the service we provide to you.
This privacy policy:
provides an overview of how Propeller Ads collects and processes your personal data, and informs you about your rights under the EU General Data Protection Regulation (“GDPR”) and any national law supplementing or implementing the GDPR,
contains important information about, among others, the collection and use of personal data; the legal grounds for the processing of that data; disclosures of that personal data to third parties and the use of cookies on the Website.
For the purposes of this privacy policy:
when we refer to “personal data” we mean data which identifies or may identify you and which may include, for example, your name, address, identification number, telephone number, date of birth, occupation and family status,
when we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data, and
when we refer to our “Website” or our “Platform” we mean www.PropellerAds.com.
Who we are
Propeller Ads Ltd is a company registered in the Republic of Cyprus, under registration number HE353513 as a limited liability company having its registered office at 15, Karaiskaki Street, 3032, Limassol, Cyprus.
Propeller Ads Limited is a company registered in the Isle of Man, under registration number 011883V as a limited liability company having its registered office at First Floor, Jubilee Buildings, 26-28 Athol Street, Douglas, IM1 2SH, Isle of Man.
This Privacy Policy will apply to both Propeller Ads Ltd in Cyprus and Propeller Ads Limited in the Isle of Man.
Our Data Protection Principles
We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:
Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
Accurate and where necessary kept up to date (Accuracy).
Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
Made available to data subjects and data subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).
We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).
Privacy Policy
Date May 25, 2018
1. Data Controller
1.1 This privacy policy applies where we are acting as a data controller with respect to your personal data and therefore determine the purposes and means of the processing of that personal data.
1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our Website.
1.4 Our Website incorporates privacy controls you can use to specify whether you would like to receive marketing, limit the publication or any other use of your information. You can access such privacy controls via contact.us@propellerads.com.
2. How We Collect Your Personal Data
2.1 We obtain your personal data mainly through any information you provide directly to us or through information provided by third parties. Below is a list of ways in which we collect your personal data.
Personal data collected directly from you, including:
when you complete our Publisher or Advertiser registration forms, which are available on our Website,
when you enter and use our Website, and/or performing contractual obligations, and
when you contact us for any enquiries, complaints or for any other reason.
Personal data collected from other sources, including:
via third parties including our business partners, contractors and/or vendors in a manner that is permitted,
through tags in websites you use and/or manage or control.
3. Personal Data We Use, Purposes And Legal Grounds
We may collect the following personal data from you depending on the service we provide to you. We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Type of information Purpose Legal basis of processing
Data about your use of our Website.
IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, timing, frequency, pattern of your service use.
To analyse the operation of our Website and services.
Legitimate interests in monitoring and improving our Website and services.
Profile data.
Your name, address, telephone number, email address, gender, date of birth.
Operating our Website, providing our services, communicating with you. Fulfilment of KYC/AML procedures.
Legitimate interests in the proper administration of our Website.
Performing the contract we have with you.
Publication data.
Information that you post for publication on our Website or through our services.
The publication data may be processed for the purposes of enabling such publication and administering our Website and services.
Legitimate interests for the proper administration of our Website and business.
Performing the contract we have with you.
Inquiry data.
The inquiry data may be processed for the purposes of fulfilment of our KYC and AML obligations. The proper performance of our payment obligations to you.
Performing the contract we have with you.
Transaction data.
The transaction data your contact details, your card details and the transaction details.
The transaction data may be processed for the purpose of payments and keeping proper records of those transactions.
Performing the contract we have with you.
Notification data.
The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
Consent. Performing the contract we have with you.
Correspondence data.
The communication content and metadata associated with the communication.
The proper performance of our contractual obligation before you.
Consent. Performing the contract we have with you.
Any of your personal data identified in this policy.
Exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Our legitimate interests.
Any of your personal data identified in this policy
The obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice.
Our legitimate interests.
4. Information We May Provide To Third Parties
We may disclose your personal data to the third parties listed below.When we do so, we require those third parties to have appropriate technical and organisational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the purposes described in this privacy policy, nor will we sell your personal data to anyone.
4.1 Any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this privacy policy.
4.2 To our insurers and/or professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 Payment services providers we have chosen to support us with financial transactions relating to our Website. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.4 Governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings or investigations by such parties or in order to enable Propeller to comply with its legal and regulatory requirements.
4.5 Partners, contractors and/or vendors in order to perform contract we have with you.
5. Your Data Protection Rights
You have the following rights in terms of the personal data we hold about you:
The right to be informed.
Propeller Ads is publishing this privacy policy to keep you informed as to what we do with your personal data. You can ask us for information regarding any data of yours that we keep at any time. This information concerns, among other things, the data categories we process, for what purposes we process them, the origin of the data if we did not acquire them directly from you and, if applicable, the recipients to whom we have sent your data.
The right to access.
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can obtain a copy of your data from us free of charge. If you are interested in other copies, we reserve the right to charge for the additional copies.
The right to correction (rectification).
You can request that we correct your data. We will initiate appropriate measures to keep the data of yours that we continuously process correct, complete, and up to date, based the latest information available to us.
The right to erasure
(The right to be forgotten).
You can request that we delete your data provided the legal requirements have been met. In accordance with Article 17 the GDPR, this can be the case if:
the data are no longer required for the purposes they were acquired or otherwise processed;
you revoke your consent, which is the basis of the data processing, and there is no other legal basis for the processing;
you object to the processing of your data and there are no legitimate reasons for the processing or you object to data processing for the purposes of direct advertising;
the data have been processed illegally.
Where the processing is not necessary:
To ensure adherence to a legal obligation that requires us to process your data
In particular with regard to legal retention periods
To assert, exercise or defend against legal claims
The right to restrict processing.
You can request that we restrict the processing of your data if
You dispute the correctness of the data – for the period of time we need to check the correctness of the data;
The processing is illegal but you do not wish to have your data deleted and request a restriction of use instead;
We no longer need your data, but you need them to assert, exercise or defend against legal claims;
You have filed an objection to the processing, though it has not yet been decided whether our legitimate grounds outweigh yours.
The right to data portability.
At your request, we will transfer your data– where technically possible – to another responsible entity.
However, this right only applies if the data processing is based on your consent or is required to fulfill a contract. Instead of receiving a copy of your data, you can ask us to send the data directly to another responsible entity that you specify.
The right to object.
You can object to the processing of your data at any time for reasons that arise from your special situation provided the data processing is based on your consent or our legitimate interest or that of a third party. In this case, we will no longer process your data. The latter does not apply if we are able to prove there are compelling, defensible reasons for the processing that outweigh your interests or we require your data to assert, exercise or defend against legal claims.
The right to withdraw consent.
Withdraw the consent you gave us with regard to the processing of your personal data for certain purposes, such as to allow us to promote our products and services to you.
The right to complain.
Propeller Ads takes your rights very seriously. However, if you are of the opinion that we have not dealt with your complaints adequately, you have the right to submit a complaint to the data privacy protection authorities responsible. You can visit their website to find out how to submit a complaint (http://www.dataprotection.gov.cy).
We endeavour to address all of your requests promptly.
6. International Transfers Of Your Personal Data
6.1 We may transfer your personal data to our offices in the Isle of Man, where the European Commission has determined that the territory provides adequate protection for the privacy rights of individuals. We will only do so when it is necessary for one of the purposes set out in this Privacy Policy.
6.2 We do not envisage that any of your personal data will be transferred to any other countries outside the European Economic Area (EEA) as our offices, facilities, subcontractors and other third parties with which we work are all located within the EEA.
6.3 In the event that this changes in the future and one or more recipients of your personal data are located outside the EEA, where data protection laws may be of a lower standard than in the EEA, we will impose the same data protection safeguards that we deploy inside the EEA to ensure that your personal data are always protected.
7. Retaining And Deleting Personal Data
7.1 We will keep your personal data for as long as is necessary for the purpose for which we initially collected them. Once such period has ended, we will keep your personal data for the longest of the following periods: a) any retention period set out in our retention policy which is in line with regulatory requirements relating to retention; or (b) the end of the period in which legal action or investigations might arise in respect of the services provided.
7.2 Once the retention period of your personal data lapses, we will ensure that your personal data are either irreversibly anonymised or securely destroyed.
8. Confidentiality And Security
8.1 We deploy various security measures such as encryption and authentication tools in line with the current state of the art to protect and maintain the security, integrity and availability of your personal data.
8.2 100% protection against unauthorised access in the case of data transfers across the internet or a website cannot be guaranteed, but we and our service providers and business partners do our utmost to protect your personal data in line with the prevailing data protection legislation by means of physical and electronic physical precautions. Among other things, we use the following measures:
Strict criteria for authorisation to access your personal data on a “need-to-know” basis only and exclusively for the specified purpose;
Transfer of acquired data in secured form;
Storage of confidential data in our secure servers;
Firewall safeguarding of IT systems to provide protection against unauthorised access, and
Continuous monitoring of access to IT systems to detect and prevent the misuse of personal data.
8.3 If you have received a password from us in order to be able to access certain parts of our Website, you are responsible for keeping this password confidential and for compliance with all other security procedures which we make you aware from time to time. We ask you not to share your password with anyone.
9. Cookies
9.1 Our Website uses cookies to distinguish you from other users of the Website and provide contractual obligations in a high quality level. This helps us to ensure its smooth operation in order to improve your experience. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies Policy at https://propellerads.com/cookies/
10. Changes To This Privacy Policy
10.1 We may update this privacy policy from time to time by publishing a new version on our Website.
10.2 We will notify you appropriately when we make changes to the privacy policy and we will amend its revision date so that you know when we last amended it. We do however encourage you to review this statement periodically so as to always be informed about how we are processing and protecting your personal information.
10.3 We may notify you of changes to this policy by email or through the private messaging system on our Website.
11 Contacts
11.1 If you have any questions about our privacy policy or wish to obtain more details in relation to the personal data we process about you or wish to exercise any of your rights set out in Section 5, please contact us via email at: contact.us@propellerads.com