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MATOMY MEDIA GROUP LTD. PRIVACY POLICY

Updated on May 24th 2018

 

Matomy Media Group Ltd. and its subsidiaries (“Matomy”, “we”, “Us” or “Our”) put great efforts in making sure that we secure your personally identifiable information and use properly.

Matomy is an international digital marketing company providing advertisers, agencies, publishers and application developers (“Customers”) with a wide range of digital and programmatic advertising solutions (“Service”).

This policy explains our privacy practices for processing personally identifiable information on Matomy’s advertising solutions and platforms (the “Service”) and Matomy’s Website (the “Site”). We process your personally identifiable information subject to the terms of this policy.

Chapters of the Privacy Policy:

Matomy provides data driven technology to Matomy’s Customers.

The Service

Matomy provides Customers custom digital and programmatic based advertising solutions supported by large data analytics, proprietary platforms and optimization technologies. As such, Matomy has no direct interaction with the individuals that visit Customers’ websites (“Users”).

The personally identifiable information Matomy collects is typically used for Real-Time Bidding " complex technological tools or platforms that enable advertising buyers to bid in “real time" for the opportunity to show an online advertisement when a web page is loaded, or an app is used by the User.

Customers required, according to Matomy’s agreements with Customers, to provide an appropriate notice to Users about this Privacy Policy.

We collect information you provide to our Customers and information about your device.

The Personally Identifiable Information That We Collect

Matomy collects personally identifiable information in several ways (as described below) to provide the Service and for other specific purposes, as described in this policy. Please note that you are not required by law to provide us personally identifiable information. Data collected through Customers’ websites and ads When Users engage with Customers’ website or Customers’ ads, we will obtain the following types of personally identifiable information through our engagement with Customers:
  1. Data that User provides to the Customers, including registration details, age, gender and geo-location;
  2. Data about User’s device, including device dimensions, model, manufacturer, operating system and the origin of the data (the application or website that User used);
  3. IP address and connection type;
We obtain such information by using digital identifiers. You can find more information on our digital identifiers below:
  • Beacons, Pixels and Tags: Beacons (also sometimes referred to as web beacons or pixels) and tags enable online advertising companies to collect data, serve advertising, and provide related services, such as measurement or fraud prevention, on websites by allowing communication between a web browser and a server. A beacon is a small transparent image that is placed on a web page.
  • A tag is a small piece of computer code that is run by the web browser.
  • Mobile SDK: A mobile SDK is the mobile app version of a beacon or tag (see Beacons and Tags above). The SDK is a piece of computer code that publishers include in their apps to enable ads to be shown and to enable related services, such as measurement or fraud prevention, including by collecting and analyzing data which is available through the device on which the mobile SDK is installed.
  • Cookie: A cookie is a small text file that is stored in a web browser by a website or ad server. By saving information in a cookie, websites and servers can remember preferences or recognize browsers from one visit to another or from one website to another.
  • Non-Cookie Technology: Today’s online world is becoming increasingly complex, with a proliferation of new devices, software platforms, online services and other technology. As such, cookies are not always available. Therefore, companies are using alternative methods to distinguish devices. For example, some platforms, such as Apple’s iOS and Google’s Play Services for Android, provide unique IDs to be used for advertising. Most mobile devices are assigned unique identifiers that also may be used to distinguish devices. Additionally, it is possible to use mathematical techniques to make intelligent guesses about recognizing devices.

We automatically log 'traffic/session' information including IP addresses and user agent.

We collect session durations and additional activity information If you register with the Service we will need your name, your company name, email address and password, for registration and notice purposes.

We will receive any personally identifiable information that you provide when commenting on our blog or site and when contacting us.

Our Site and Blog

When you access our Site or Blog, our servers log certain 'traffic/session' information from your device, such as your user agent and the Internet Protocol (IP) address.

When you use our Site or Blog, we collect information about your activity, for example your log-in and log-out time, the duration of sessions, viewed web-pages or specific content on web-pages, activity measures and geo-location of your device.

If you register with the Service we will need information such as your name, your company name, email address and password, for registration and notice purposes and your payment details to process your payment for the Service.

The Site will also include links to third-party social media websites such as Facebook®, Twitter®, LinkedIn® and Google+®, as well as associated social media features and scripts, such as the Facebook® “like” button and widgets.

These features and scripts will collect your IP address, which page you are visiting on the Site, and will set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by the applicable third party social media website or hosted directly on the Site.

Your interactions with these social media features and widgets, as well as your interactions with the social media websites themselves, are governed by the privacy policies of the applicable social media websites.

If you submit personally identifiable information in a comment on a blog post or on any applicable social media website, you should be aware that the personally identifiable information that you submit can be read, collected or used by others and could be used to send you unsolicited messages or otherwise contact you without your consent or desire.

We are not responsible for the personally identifiable information that you choose to submit in these forums.

When you contact us, or when we contact you, we will receive and process any personally identifiable information that you provide us.

We display personal testimonials of satisfied Customers on the Site in addition to other endorsements. With your consent we will post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at: [email protected]

We maintain the Service, make it better and continue developing it, and protect us and the Service from misuse and law violations.

What Do We Do with Personally Identifiable Information?

We use the personally identifiable information we collect and receive to provide the Service, to enable the Service's tools and features, to study and analyze the functionality of the Service and Customers’ and Users' activities, to provide support, to measure Service activity for pricing purposes, to maintain the Service, to make it better and to continue developing the Service.

We will use Customer’s email address to contact Customer when necessary, to send reminders and to provide information and notices about the Service. We will include commercial and marketing information.

We obey the law and expect you to do the same. If necessary, we will use personally identifiable information to enforce our terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service, and to take any action in any legal dispute and proceeding.

We commit to process personally identifiable information solely for the purposes described in this policy.

We use service providers, for example, to process payments and send email messages. We will transfer information as needed if we change our corporate structure, and we will share the information with our affiliate entities.

Sharing Personally Identifiable Information with Others

We will share your personally identifiable information with service providers and other third parties, if necessary to fulfill the purposes for collecting the information, provided that any such third party will commit to protect your privacy as required under the applicable law and this policy.

We will also share personally identifiable information with companies or organizations connected, or affiliated with us, such as subsidiaries, sister-companies and parent companies, with the express provision that their use of such information must comply with this policy.

We will report and share user personally identifiable information, if we believe that we are required to do so by law. We will need to disclose personally identifiable information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Additionally, a merger, acquisition or any other structural change will require us to transfer your personally identifiable information to another entity, as part of the structural change, provided that the receiving entity will comply with this policy.

Aggregated data is not identifiable. We use it for legitimate business purposes and will use standard analytical tools.

Aggregated and Analytical Information

We use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies and they use their own cookies to provide their service (for further information about cookies, please see the 'Cookies' section in this policy).

We use the standard analytics tools of Google Analytics and we will use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: http://www.google.com/analytics/learn/privacy.html.

We use anonymous, statistical or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you.

You can opt-out of our mailing lists and terminate your use of the Service. You can request Matomy to stop collecting any personally identifiable information about you.

Our Service does not respond to Do Not Track (DNT) signals. If you are a California resident, you are entitled to your California privacy rights.

Your Choice

At any time, you can unsubscribe from our mailing lists or newsletters, by sending us an opt-out request to: [email protected].

At any time, you can disable your account through your account page.

At any time, you can exercise your following opt-out options: (i) object to the disclosure of your personally identifiable information to a third party, other than to third parties who act as our agents to perform tasks on our behalf and under our instructions, or (ii) object to the use of your personally identifiable information for a purpose that is materially different from the purposes for which we originally collected such information, pursuant to this policy, or you subsequently authorized such use. You can exercise your choice by contacting us at: [email protected].

We request and collect minimal personally identifiable information that we need for the purposes that we describe in this policy. Following the termination or expiration of the Service, we will stop collecting any personally identifiable information from or about you. However, we will store and continue using or making available your personally identifiable information according with our data retention section in this policy.

Some web browsers offer a "Do Not Track" ("DNT") signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on the Service or through cross-site user tracking. Our Service does not respond to DNT signals.

Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personally identifiable information relating third parties to which we have disclosed certain categories of personally identifiable information during the preceding year for the third parties’ direct marketing purposes. To make such a request, please contact us at: [email protected]

At any time, you can request access to your personally identifiable information.

Accessing Your Personally Identifiable Information

If you find that the information on your account is not accurate, complete or up-to-date, please provide us the necessary information to correct it.

At any time, you can contact us at: [email protected] and request to access the personally identifiable information that we keep about you. We will need to ask you to provide us certain credentials to make sure that you are who you claim to be and to the extent required under the applicable law, will make good-faith efforts to locate your personally identifiable information that you request to access.

If you are eligible for the right of access under the applicable law, you can obtain confirmation from us of whether we are processing personally identifiable information   about you, and receive a copy of that data, so that you could:

  • verify its accuracy and the lawfulness of its processing;
  • request the correction, amendment or deletion of your personally identifiable information if it is inaccurate or if you believe that the processing of your personally identifiable information is in violation of applicable law.

We will use judgement and due care to redact from the data which we will make available to you, personally identifiable information related to others.

If we process your personal data when you are in the EU, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws.

Your EU Data Subject Right

If EU data protection laws apply to the processing of your personal data by Matomy, then the following terms apply:

For the purposes of Matomy advertising solutions and platforms, we are a data processor and our Customers are data controllers, or data processors as well. Matomy's data processing addendum, which is available at: https://www.mobfox.com/terms-of-service/ or upon request, applies to such processing.

Where we process your personal data as a data controller, the processing is based on the following lawful grounds:

  • All processing of your personal data which are not based on the lawful grounds indicated below, are based on your consent.
  • We process your account and payment details to perform the contract with you.
  • We will process your personal data to comply with a legal obligation and to protect your and others' vital interests.
  • We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
  • Communications with you, including direct marketing where you are our client or a user of our client, or where you make contact with us through our website and other digital assets.
  • Cyber security
  • Support, customer relations, service operations
  • Enhancements and improvements to yours and other users' experience with our services.
  • Fraud detection and misuse of the Service.
In addition to your rights under other sections in this policy, you have the following rights:
  • AT ANY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA. EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
  • Request to delete or restrict access to your personal data. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
  • If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you can request to be informed that third parties that hold your personal data, in accordance with this policy, will act accordingly.
  • You can ask to transfer your personal data in accordance with your right to data portability.
  • You can object to the processing of your personal data for direct marketing purposes. Additional information about this right is available under the Choice section in this policy.
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
  • You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR.

A summary and further details about your rights under EU data protection laws, is available on the EU Commission's website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will ask you further questions to understand the nature and scope of your request.

If we need to delete your personal data following your request, it will take some time until we completely delete residual copies of your personal data from our active servers and from our backup systems.

If you have any concerns about the way we process your personal data, you are welcome to contact our data protection officer at: [email protected]. We will look into your inquiry and make good-faith efforts to respond promptly.

Representative in the EU

For any details regarding our compliance with data protection provisions and to exercise your EU data subject rights, you can also contact our EU representative at: Matomy UK Ltd, 14 Grays Inn Rd, London WC1X 8HN.

We retain data as needed, to provide the service and for legitimate and lawful purposes.

Data Retention

We retain different types of personally identifiable information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law.

For example, we will need to keep the information for several years due to tax related requirements, for accounts settling, record keeping, archiving and legal issues.

We will maintain your contact details, to help us stay in contact with you. At any time before or after the termination of your account, you can contact our data protection officer at: [email protected] and request to delete your contact details. Note that we will keep your details without using them unless necessary, and for the necessary period, for legal requirements and proceedings.

We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

As a Customer, as long as you use the Service, we will keep information about you, unless the law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this policy.

We will store and process information in various sites throughout the globe, including in sites operated and maintained by cloud-based service providers.

Transfer of Data Outside Your Territory

We will store and process information in various sites throughout the globe, mainly in the US including in sites operated and maintained by cloud-based service providers. If you are a resident in a jurisdiction where transfer of your personally identifiable information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer.

To the extent necessary under EU privacy laws and regulations, we will implement data onward transfer instruments, such as the Controller to Processor SCCs, the Controller to Processor SCCs, the Privacy Shield Framework and a statement of compliance with the Privacy Shield Principles, and such other lawful instruments to transfer personally identifiable information, as may be available from time to time.

We use cookies to make it easier for you to log-in and to facilitate Service activities.

Cookies and Other Tracking Technologies

Cookies are small files that a web server sends to a user's device, when the user browses online.

Your device removes session cookies when you close your browser session. Persistent cookies last for longer periods. You can view the expiry date of each cookie, through your browser settings.

We use both types. We use persistent cookies to remember your log-in details and make it easier for you to log-in the next time you access the Service. We use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Service's features and tools.

Every browser allows you to manage your cookies preferences. You can block or remove certain cookies, or all of them through your browser settings. Please bear in mind that blocking or removing cookies will have an effect on your user experience with our Service/ For example, you will need to re-enter your log-in details, or even prevent you from using features of the Service.

We also use clear gifs which are tiny graphics with a unique identifier (but do not retain any personally identifiable information), which are used to count user or visitor visits/clicks to web pages while using the Service.

We implement systems, applications and procedures to secure your personally identifiable information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

Information Security

We and our hosting services implement systems, applications and procedures to secure your personally identifiable information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Contact us at: [email protected] or write us for every request and complaint. We will make good-faith efforts to resolve any existing or potential dispute with you.

Dispute Resolution

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when we believe that we need to, and to verify that we display the policy properly and in an accessible manner. If you have any concerns about the way we process your personally identifiable information, you are welcome to contact our data protection officer at: [email protected], or write to us. Our address is published on our website at: www.matomy.com and, if applicable, is indicated in your subscription agreement with us.

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

We will update our policy from time to time after giving proper notice.

Changes to this Privacy Policy

From time to time, we will update this policy. If the updates have minor if any consequences, they will take effect 7 days after we post a notice on the Service's website. Substantial changes will be effective 30 days after we initially posted the notice.

Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then-existing policy you can choose not to accept it and terminate your use of the Service. Continuing to use the Service after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.

Contact Us

Please contact our Data Protection Officer at: [email protected] for further information.