When processing personal data, the Company is guided by and complies with the General Data Protection Regulation (“GDPR”) and any other applicable legal acts governing the protection of your personal data.
In case you would like to exercise any of your rights provided in this notice, you may submit such inquiries and requests by means provided in the Contacts section.
PRINCIPES OF DATA PROCESSING
We are guided by the following personal data processing principles:
- Personal data is processed in a lawful, fair and transparent manner (principle of lawfulness, fairness and transparency);
- Personal data shall be processed for specified, explicit and legitimate purposes and shall not be further processed in a manner incompatible with those purposes (purpose limitation principle);
- Personal data are appropriate, relevant and only necessary for the purposes for which they are processed (principle of data minimization);
- Personal data are accurate and updated as necessary (principle of accuracy);
- Personal data shall be kept in a form that permits identification of the person for no longer than is necessary for the purposes for which the personal data are processed (the principle of limitation of storage period);
- Personal data shall be processed in such a way as to ensure, through appropriate technical or organizational measures, adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage (integrity and confidentiality principle).
PERSONAL DATA WE PROCESS AND PERSONAL DATA PROCESSING PURPOSES
We process the following data for the following purposes:
- Information that you provide to us for the purpose of subscribing to our email messages and newsletters. The legal basis for this processing is your consent and if we have already provided services for you via our Website, we may also process the indicated data on the basis of our legitimate interest, namely seeking to suggest our similar services to you. You have the right to withdraw your consent and/or object to the processing at any time.
- Information relating to any communication that you send to us. This data may include the communication content (for example, email address and content of the message) and metadata associated with the communication (for example, device system name, system version, model). The legal basis for this processing is your consent and/or our legitimate interests, namely for investigating any disputes that may occur between you and us.
- Any information identified in this notice where necessary for the establishment, exercise or defense of legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights.
- Any information to the necessary extent where such processing is necessary for compliance with a legal obligation to which we are subject.
Please note that we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
PERSONAL DATA RETENTION PERIODS
We will store your data for the following periods:
- information that you provide to us for the purpose of subscribing to our email messages and newsletters – will be retained for no longer than 2 (two) years following the provision of consent or, in case the messaging data is being sent to the present clients in order to maintain and improve customer relations, for no longer than 2 (two) years following the end of the provision of the respective services, unless you respectively withdraw your consent earlier or object to such processing;
- information relating to any communication that you send to us – will be retained for no longer than 6 (six) months following the end of such communication unless you withdraw your consent earlier;
- information on your use of our Website as well as on your device when you are browsing our Website – will be retained for no longer than 2 (two) years following the provision of your consent or, in case processing of device data is based on our legitimate interest (e.g, for proper management of our Website), such device data will be processed as long as it is necessary to fulfil our legitimate interest.
- any information identified in this notice where necessary for the establishment, exercise or defense of legal claims – will be retained until an appropriate decision or conclusion is made by law enforcement authorities or a court or any other decision or conclusion by the persons investigating the incident or by other persons investigating the event that has caused damage to the Company.
- any information to the necessary extent where such processing is necessary for compliance with a legal obligation to which we are subject – will be retained as long as it is indicated in the relevant laws.
After the end of the applicable retention period, or upon your request, personal data is irreversibly destroyed using overwriting or physical destruction (when applicable) methods.
PERSONAL DATA DISCLOSURE
The Company may disclose your personal data to our service providers insofar as it is reasonably necessary to provide specific services (including providers of servers and maintenance thereof, email service providers, support and development service providers, service providers used for data analysis or marketing, call centres, customer satisfaction surveys or market research).
The Company may also disclose your personal data to other third parties insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations, obtaining professional advice, or establishing, exercising or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Persons or legal entities indicated in this Section may be established outside the European Union and European Economic Area. In case we transfer your personal data to such persons, we will take all the necessary and the legal acts indicated measures to ensure that your privacy will remain properly secured, including, where appropriate, signing standard contractual clauses for the transfer of data. To find out more information regarding appropriate safeguards, you may contact us via email: [email protected]
If we have your prior consent, we can contact you via email or phone to inform you what we are up to.
You may opt out of receiving any marketing communications at any time. You may do so by choosing the relevant link in any of our marketing messages or contacting us via means provided on our Website. If you are receiving both email and phone marketing communications and you wish to opt out of receiving them, you will need to opt-out separately by following the relevant link in any of our marketing messages or contacting us via means provided on our Website.
Please be informed that the withdrawal of consent shall not affect the lawfulness of processing based on consent carried out before the withdrawal of consent.
In case you opt out of receiving marketing communications, we will immediately stop sending marketing communications to you. Nevertheless, please be informed that as our business activities consist of a network of closely related services, in certain cases, it may take a few days until all the systems are updated, thus, you may continue to receive marketing communication while we are still processing your request.
PERSONAL DATA PROTECTION
We are using a number of technical and organizational means to protect your personal data. Organizational security measures include restricting access solely to authorized persons with a legitimate need to access personal data, signing confidentiality agreements, arranging training, and creating and implementing relevant policies and procedures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorized access, implementing access control and authentication tools, ensuring physical security etc.
YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
(a) the right to be informed about the processing of personal data. You have the right to obtain information about the personal data processed by us, the sources of the personal data, the purposes of the processing, the legal grounds, the retention period, data recipients or data processors, your rights etc.
(b) the right to access data. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information.
(c) the right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
(d) the right to the erasure of your personal data. You have the right to request the erasure of your personal data if it is no longer necessary for the purpose for which personal data were collected, and/or you withdraw consent to the processing of your personal data if the processing was based on your consent, and/or we are processing your personal data on the basis of legitimate interest and you object to such processing, and there are no overriding legitimate reasons for processing the data, and/or we are required to delete your personal data in order to comply with a legal obligation imposed on the Company, and/or your personal data has been processed unlawfully.
(e) the right to restrict the processing of your personal data. You have the right to restrict the processing of personal data by the Company if you dispute the accuracy of the data and the Company carries out a related check, and/or if the personal data of you have been unlawfully processed but you do not consent to the erasure of the data, and/or if the personal data of you are no longer necessary for the purpose, for which it was collected, but is necessary for the establishment, exercise or defense of legal claims by you, if you have objected to the processing as described below, pending verification that the Company’s legitimate reasons override those of you.
(f) the right to object to the processing of your personal data. You have the right to object to the processing of your personal data by the Company for direct marketing purposes, scientific or historical research purposes or statistical purposes, and the right to object to the processing of personal data in the public interest or in the legitimate interests of the Company, unless these interests are overridden by your reasons.
(g) the right to data portability. You have the right to receive the personal data you have provided to the Company or to request the transfer of such personal data to another controller in a structured, commonly used and computer-readable format, provided that the processing of your personal data is based on your consent or on an agreement between you and the Company and the processing of the personal data of you is carried out by automatic means.
(h) the right to complain to a supervisory authority. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is supervised by the State Data Protection Inspectorate of the Republic of USA.
(i) the right to withdraw consent. To the extent that the legal basis for our processing of your personal information is your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(j) the right to request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Except for the following exclusions from this right: (i) a decision is necessary for entering into, or performance of, a contract between you and us; (ii) a decision is authorized by EU or EU member state law to which we are subject to and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; (iii) a decision is based on your explicit consent.
You may contact the Company via e-mail at [email protected] to exercise your rights. The Company has a right to request you to confirm your identity.
We undertake to respond to such inquiries within 1 month after they are received. This response time may be extended by 2 months for complex or multiple requests. In case of such an extension, we will inform you additionally.
Cookies are small textual files containing an identifier that is sent by a web server to your web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
On the Website, we use the following cookies for the following purposes:
- Required cookies – used to ensure proper performance of the Website, security of customers and their data, and provision of high-quality services;
- Functional cookies – used to enhance the Website user experience, analyse the use of the system and, in accordance with such, improve the provision of services;
- Advertising cookies – used to observe user online behaviour and optimize marketing campaigns according to such information.
COOKIES USED BY OUR SERVICE PROVIDERS
We may use:
HOW CAN YOU MANAGE COOKIES?
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via the information provided in the relevant browser website, for example, Chrome, Firefox, Internet Explorer, and Safari.
Blocking all cookies will have a negative impact on the usability of many websites. If you block cookies, you will not be able to use all the features on our Website.
THIRD PARTY WEBSITES
The Website may include links to third-party websites, plug-ins and applications and certain content on the Website may be hosted and served by third parties that we do not control. When you click on a link to any other website or location, you will leave our Website and go to another site and another entity may collect personal Information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content.
MEDIAVINE PROGRAMMATIC ADVERTISING (VER 1.1)
The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.
First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.
Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.
The Website collects the following data using a cookie when serving personalized ads:
- IP Address
- Operating System type
- Operating System version
- Device Type
- Language of the website
- Web browser type
- Email (in hashed form)
Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.
If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.
CHILDREN PERSONAL DATA
Our Website services are targeted at persons over the age of 18.
If we have reason to believe that we hold the personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that personal data.
CALIFORNIA PRIVACY ADDENDUM
- We do not knowingly sell personal information nor share it with third parties for direct marketing purposes. However, if we do so in the future, you will be notified and have the right to opt-out of the “sale” of personal information;
- You have the right to not be subject to discrimination if you exercise any of your rights.
- We do not currently recognize or respond to browser-initiated Do Not Track signals. Instructions to enable the following browsers are here: Chrome, Firefox, IE, Edge, Safari, and Opera.
UPDATING YOUR DATA
Please let us know if the personal data that we hold about you needs to be corrected or updated.
In case of any inquiries or if you would like to exercise any of your rights provided in this notice, you may submit such inquiries and requests by the following contact details:
Email address – [email protected]
CHANGES TO THE NOTICE