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We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:
We obtain your personal data mainly through any information you provide directly to us or through information provided by third parties. We collect personal data directly from you when you complete Publisher or Advertiser registration forms 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.
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|
Your name, address, telephone number, email address, PayPal address, your bank account data.
|Operating our Website, providing our services, communicating with you. Fulfilment of KYC/AMLprocedures.||Legitimate interests in the proper administration of our Website.
Performing the contract we have with you.
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.|
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.|
Under the Data Protection legislation you have the following rights in terms of the personal data we hold about you.
The right to be informed about the collection and the use of their personal data
The right to access personal data and supplementary information
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 have inaccurate personal data corrected, or completed if it is incomplete
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 (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:
Where the processing is not necessary:
The right to restrict processing in certain circumstances
You can request that we restrict the processing of your data if
The right to data portability, which allows the data subject to obtain and reuse their personal data for their own purposes across different services
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 to processing in certain circumstances
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 at any time
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.
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. Once the retention period of your personal data lapses, we will ensure that your personal data are either irreversibly anonymized or securely destroyed.
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. 100% protection against unauthorized 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:
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.
Date: September 4, 2018