§ I. General information
- Whenever necessary you can contact us traditionally by writing to the address of our headquarter (indicated in point 1) above), by e-mail: email@example.com and by phone: 00 48 22 535 30 50.
§ II. Collected and processed data
- In this section we have set out:
- the general categories of data that we process;
- the source and specific categories of personal data – for personal data we do not obtain directly from you;
- the purposes for which we process personal data; and
- the legal bases of the processing.
- We process information about your use of our services we render and services that are provided by our clients. This information is not personal data ("usage data"). The usage data may include numbers of users requesting services managed by us and our partners, along with time and duration of visits, numbers of users displaying our advertisements, technical data of users’ web browsers and operating systems, data of effectiveness of our advertisements, including amount of clicks they generated, interest category or categories, to which users have been assigned to, anonymized IP addresses.
- The source of the usage data is our analytics system or our partners’ systems.
- This usage data may be processed by us and our Partners indicated in point 13 below for the purposes of analyzing the use of the website and services, ad targeting, modelling, R&D. The legal basis for this processing is consent of the user (collected through our website or through website of our partners) and our legitimate interests, namely advertising services of ours or of our clients’.
- We will take reasonable steps to ensure that end user is provided with clear and comprehensive information about, and gives consent to, the storing and accessing of cookies and other information on the end user's device where such activity occurs and where providing such information and obtaining such consent is required by law.
- We do not collect, use and process any personal data, including personal data of users such as name, age, address, gender, place of residence, personal identification numbers, e-mail, phone numbers etc. Also, we do not receive any additional data from our clients, which, along with data collected by our technology, would enable us to directly identify you.
- We do not collect, use and process sensitive personal data (such as data about religion, political opinion, health etc.).
- We do not collect, use and process the data, in particular in interest-based advertisements, any data from users known to us to be under the age of 16 years, any data from websites directed to children under the age of 16 years, any data originating from adult, gambling or 2 governmental websites, and any other sensitive information such as financial or health status, race, commission of crime, political beliefs, sexual orientation etc.
- We collect Usage data in order to increase the relevancy of the ads being displayed to you i.e. advertisements of products they may be likely interested it, and other advertising-related purposes. Estimation of advertisements which may be of interest to a user is made by checking past browsing behavior of a user based on a cookie stored by the user’s web browser, and by assigning the user to one or more interest categories. Information collected through ads are also used for subsequent use in targeting or re-marketing. Statistical (not individual) information about users and effectiveness of advertisements may be passed to our customers – advertisers, in order to allow them to make informed decisions regarding their advertising campaigns and assess their effectiveness. Information may be also passed to third parties if it is technically required to display advertisements to users. We will also pass data if required by applicable law.
- The Usage data we collect is also used for reporting purposes, to give our clients and partners indicated in point 13 below more information about the performance of their advertising campaigns, and to improve performance over time.
- The Usage data do not directly identify an individual and is not considered to be personal information, but specific types of the information such as non-anonymized IP address, cookies, may be considered personal information in EU/EEA or if combined with other information. If such information may be considered personal information we treat this information as personal information.
- If we or our client or partner obtain personal data and has no legal basis for the access to and processing of that data, we or our client or partner should quickly cease collection and storage of the data and refrain from passing the data on to other parties, even if those parties have a legal basis.
- We may share the data collected with third parties including:
- Adobe https://www.adobe.com/pl/privacy/policy.html
- Adform https://site.adform.com/privacy-center/overview/
- AppNexus https://www.appnexus.com/platform-privacy-policy
- Eyeota, https://www.eyeota.com/privacy-policy/
- Google, https://policies.google.com/privacy?gl=pl
- Liveramp, https://liveramp.com/privacy/
- Lotame, https://www.lotame.com/about-lotame/privacy/
- MediaMath, http://www.mediamath.com/privacy-policy/
- Nielsen, http://www.nielsen.com/pl/pl/privacy-policy.html
- Oracle https://www.oracle.com/legal/privacy/marketing-cloud-data-cloud-privacypolicy.html
- The Tradedesk https://www.thetradedesk.com/general/privacy
- Omnicom Media Group https://www.omnicommediagroup.com/disclaimer.htm
Please consider checking the privacy policies of the above entities.
- We may share the data collected within the capital group including OnAudience, Online Advertising Network, Audience Network.
- We follow the IAB Transparency & Consent framework (http://advertisingconsent.eu/).
§ III. Cookies and other technical means
- We are storing on users’ computer systems telephone or other device from which you access cookie files (short text files) containing in particular information on user’s interest category and advertisements clicked by the user.
- We are also using other technical means necessary to provide its advertising services, such as web beacons and pixels.
- Cookie files:
- collect data regarding your use of the Website, and their main purpose is to facilitate the use of the Website and customize the Website to your needs and expectations;
- are placed on the User’s end device and may also be used by advertisers and partners cooperating with us;
- do not store information constituting personal data of the User (stored information is the following: user’s ID, timestamp, anonymized geolocation);
- are not used to determine the identity of the User;
- are used on the Website, based on the acceptance of recommended settings of the Website User expressed through appropriate software settings, in particular through a web browser.
- We may also process personal data enclosed in your application for the purposes of conducting recruitment processes (“recruitment data“). Such processing is carried out on the basis of your consent. We may process your recruitment data until the end of a recruitment process, unless we have your consent to process data in future recruitment processes – in such cases we may process your recruitment data until you withdraw your consent or until we decide that your data is no longer necessary or may not be up to date.
- You may at any time revoke or change the scope of any previously expressed consent to use cookie files on the Website and delete them from your browser.
- You may also at any time limit or disable cookie files in your browser through the settings. In this case, however, your use of the Website may be less efficient, you may not have access to certain content or be able to use some of the Website's functionalities, and in extreme cases the correct display of the Website pages may be completely blocked.
- We use the following types of cookies:
- Essential cookies: These are the cookies necessary to enable the user to navigate and use their functions. These types of cookies do not collect any information about the user that could be used for marketing purposes, nor do they remember sites visited by the user on the Internet.
- Performance cookies: These are cookies that collect information about how the user uses websites, for example which pages are most frequently visited. They do not collect user identification information. All information collected is anonymous. Their task is to improve the efficiency of websites.
- Functional cookies: these are cookies that remember choices made by the user (such as username, language preferences or region of origin).
- Cookies for targeting advertisements: These third-party cookies are used to serve you with advertisements that are relevant to you and your interests.
§ IV. Opting out
- You may prevent data collection, processing and transmission to third parties by downloading and storing a following cookie in http://rtb.cloudtechnologies.pl a web browser it is using. If you are using more than one web browser or more than one computer system, a cookie must be downloaded and stored in each of the browsers. Clearing a browser’s cache from cookies will require re-downloading of an opt-out cookie.
- You may also disable cookies and local storage in its web browser. However, it will hinder web browsing experience, as many websites are using cookies to store user preferences.
§ V. Your rights
- Under data protection law and “GDPR” you are entitled to:
- the right to access your data and receive a copy thereof, i.e. obtain information whether we process your personal data and specific information about such processing;
- the right to rectify (amend) their data, i.e. request to amend inaccurate personal data;
- the right to delete data, restrict the processing of data, provided that one of relevant ground for such action apply;
- the right to object to data processing;
- the right to data transfer, i.e. receive data you provided us with in a structured, commonly used and machine-readable format and if necessary to request transmitting those data to another controller;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
- If you consider that our processing of your 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.
- To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You may exercise any of your rights in relation to your personal data by written notice to us as indicated in Section 1.
§ VI. International transfers of your personal data
Should the relationship with one of our clients or partners involve cross-border data flows outside the European Union, our partner shall formally undertake to comply with the best data protection standards by adhering without any restrictions or limitations to the Standard Contractual Clauses adopted by the European Commission.
§ VII. Retaining and deleting personal data
- This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
- If we are the data processor of your personal data that we process in accordance with the data controller’s instructions such data shall not be kept for longer than specified by the data controller.
- If we are the data processor of your personal data we will retain your personal data for a minimum period of 12 months following your subscription.
- Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation.
- Usage data (aggregated) are not personal data and may be stored up to 24 months.
§ VIII. Amendments
- We may update this policy from time to time by publishing a latest version on our website. A new policy enters into force immediately after its publication on the website.
- We will inform you of any such changes via email notification or notification on our website.