Generally, there are three categories of users of the Services:“Publishers” who are operators or publishers of websites and apps;
“Advertisers” who display their content across our platform, and
“Users” who are individuals that use a Publisher’s Website or app.
Delivering of targeted and relevant content enhances your internet and mobile experience. We will collect the Personal Information that you submit to us when using the various information submission boxes and forms located within the Site.
Personal Information is data about you that is personally identifiable such as your name, postal address, email address, telephone number, credit card number and/or any other information that might be considered private. When you submit inquiries, request information or give us feedback on or in relation to this Site or you register as an Advertiser or Publisher or User, we will ask you for the relevant personal information. We may also ask you to provide other information in connection with your request, such as your location and industry, your preferred means of communication, as well as other information.
Hereinafter both Personal Information and Non-Personal Information is collectively referred to as “Information”.
If you do not wish to permit us to collect the Information about your web or mobile activity for delivering the targeted advertising, then you may access our web-based opt out tools here. You may also opt out of receiving mobile-based advertising based on our collection of mobile identifiers (such as the IDFA or the Android Ad ID) through your device “settings.” If you opt out through your web browser, we will place an opt-out cookie on your computer. If you opt out through your mobile device, we will cease tailoring content to your mobile device based on your device’s mobile identifier or precise location coordinates.
These opt-out tools tell us not to use your information for customizing content we serve. This may mean, for instance, that you may receive the same content multiple times rather than receiving new or targeted content. Please note that if you block cookies, our opt-out process may not function properly. Please also note that if you delete, block, or otherwise restrict cookies, clear your cookie cache, update your browser, override your device settings or switch devices or browsers, you will need to renew your opt-out choices.
The Non-Personal Information we obtain from your use of our Site, may be processed as follows: The IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information and geo-location. The browser for collecting information such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, time stamp and user agent string, click stream information, date and time you viewed and visited websites visited prior to your visit on our Website, operating system version and Internet browser type, language and version and cookies. We may enable Publishers to use all or some of this information through the Platform for analytics purposes and we also use this information for customizing Content to you, as described below.
Disclosure of your Information shall be subject to the below:
1. To any third-party service providers who are associated with us and who provide services such as Website hosting, data analysis, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services to enable them to provide services.
2. To identify you to anyone to whom you send messages through the Site via message boards, chat, profile pages and blogs and other services to which you can post information and materials. Any information you post or disclose through these services will become public information, and may be available to visitors to the Site and to the public. It’s your sole responsibility to maintain abundant caution when deciding to disclose your personal information, or any other information, on the Site.
3. To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including about any bankruptcy or similar proceedings).
4. As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates/partners; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
If you wish to update or amend the information which we hold about you or wish us to cease using your data or you wish to access the Information we hold about you or you don’t want to receive any marketing information from us and want us to cease to use your data for such a purpose or you want to delete your account, then please contact us at email@example.com.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).
However, do remember, that even if you delete your account, we may retain information in order to comply with laws, resolve disputes, prevent fraud etc. There may also be residual information that remains within our databases, access logs, and other records. In the event we have disclosed information as permitted under this Policy to any third party, then we shall not be responsible for update or removing such information. For email communications, you may opt out of receiving emailers, by clicking the “unsubscribe” link at the bottom of each email.
However, do note that even if you unsubscribe or opt-out, we may still send you communications related to your use of the Service.
Personal Information pertaining to individuals who are under 13 years of age is not knowingly collected or maintained. Our Website and Services is not designed to attract people under the age of 13. If we become aware of any user under the age of 13 years we take appropriate steps to remove the user’s Personal Information from our database.
We use reasonable organizational, technical and administrative measures to protect Information under our control from any unauthorized access or alterations or destruction or disclosure. Unfortunately, no systems or safeguards adopted can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at our Email Address provided above.
This Site is hosted in Unites States of America. Upon you accessing the Site you consent to transfer your information out of the country of your residence to the country where our Site is hosted and you acknowledge that in such jurisdiction the laws regarding processing of Information may be less stringent that in your country.
Where the European Union’s General Data Protection Regulation or GDPR, applies, you have rights in relation to the personal information we hold about you.
If you are a resident of the European Union (EU), when we process your personal data, we will only do so under the following circumstances:
1. In order to perform our responsibilities under a contract with our customers, such as by providing the Adoperator services you requested; or
2. We have a legitimate interest in processing your personal data, such as to send you communications about products or services that may interest you.
You have certain rights under applicable legislation, and in particular under the GDPR. We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
To exercise any of the below rights please contact us in the first instance on the above contact details.
Requests are free of charge, unless manifestly unfounded or excessive in which case we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Requests will be processed within one month of receipt but this might be extended to two months in case of a complex request, where you have made a number of requests, or if the identity of the requestor cannot be verified. In such cases, we will notify you and keep you updated, and may seek additional information to allow us to understand your request.
Please note that the Company may be subject to legal and regulatory obligations which may limit or restrict the enforcement of your rights on some occasions.
Right to information
Right of access
Right to rectification
You have the right to have any inaccurate personal data rectified and to have any incomplete personal information about you completed.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If we do hold personal data and you believe it is incorrect, you may submit a request to us to correct any alleged mistakes.
We shall communicate any rectification of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to erasure (‘right to be forgotten’)
You have the general right to request the erasure of your personal information in the following circumstances:
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
We shall communicate any erasure of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to restrict processing
Instead of requesting erasure, you also have the right to right to restrict processing of your personal information where:
We will only use your preferred communication channels to contact you, and on each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You can change your marketing preferences and/or opt-out at any time by contacting us on the above details.
Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Raising a complaint about how we have handled your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.
Right to lodge a complaint with a relevant supervisory authority
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Office of the Commissioner for Personal Data Protection Commissioner. You may contact the Office on the below details:
Iasonos 1, 1082 Nicosia, Cyprus
You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.
Last Updated: July 2019