Publishers Revenue Optimization sp. z o.o. (optad360.com)
I. PERSONAL DATA ADMINISTRATOR
The administrator of your personal data is the company Publishers Revenue Optimization sp. z o.o. with its registered office in Wrocław, Braci Gierymskich 76 Street, 51-640 Wrocław, entered in the Register of Entrepreneurs under KRS number: 0000520454, holding the Tax Registration Number (NIP): PL8943054999, share capital 6.100 PLN (hereinafter: “Administrator”) publishing at: optAd360.com.
Administrator’s contact information:
Correspondence address: Publishers Revenue Optimization sp. z o.o., Braci Gierymskich 76 Street, 51-640 Wrocław, Poland.
e-mail address: email@example.com.
II. GENERAL INFORMATION
The Administrator shall ensure that it takes special care to protect the rights and interests of persons whose personal data are processed in connection with the use of the Administrator’s website.
The Administrator shall ensure that the personal data he collects are:
1. processed in accordance with currently applicable laws,
2. processed only for the purpose of fulfilling specific purposes based on the applicable legal provisions, in particular the provisions of the General Data Protection Regulation and the Personal Data Protection Act,
3. adequate in relation to the purposes for which they are processed,
4. kept for no longer than necessary to achieve the specified purpose of processing.
1. Administrator means Publishers Revenue Optimization sp. z o.o. with its registered office in Wrocław, 76 Braci Gierymskich Street, 51-640 Wrocław, KRS 0000520454, NIP 894-30-54-999.
2. Cookies means computer data, in particular small text files, recorded and stored on the end use devices, such as computer phone, tablet. Cookies record and store certain information, which can then be accessed by information and communication systems for specific purposes. Most often they are used to optimize the process of using the website as well as to collect statistical data to identify the use of the website. Cookies are used with products: optAd360 CMP.
3. Administrator Cookies means cookies used by the Administrator, in connection with the Administrator’s operation of the Service.
4. External Cookies means cookies used by the Administrator’s partners, through the website of the Service.
5. Personal Data means information about an identified or identifiable natural person. An identifiable natural person is a person who can be identified, directly or indirectly, based on information such as name, PESEL identification number, location data, Internet identifier or one or more specific factors that determine the physical, physiological, genetic, mental, economic, cultural, or social identity of a natural person.
6. Anonymous Information means information about the User regarding his/her use of the website. Anonymous Information is provided to the Administrator through some of the tools that the Administrator uses, such as Google Analytics. However, based on Anonymous Information, the Administrator is not able to attribute the information to a specific User.
7. Processing of personal data means operation or set of operations performed on Personal Data or sets of Personal Data in an automated or non-automated manner, such as collection, recording, organizing, structuring, storing, adapting, or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise making available, matching, or linking, limiting, deleting, or destroying.
8. Profiling means any form of automated processing of personal data that involves the use of personal data needed to evaluate certain personal factors of an individual, to analyze or forecast aspects of that individual’s performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movement.
9. RODO means Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons regarding the processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
10. Newsletter means a service provided by the Administrator by electronic means, consisting of sending marketing information to the user within the scope of the Administrator’s business.
11. Service means a website, application, or service under which the Administrator operates an Internet service, operating in the domain of optad360.com.
12. Device means an electronic device through which the User accesses the Service.
13. User means a natural person, using the Service.
IV. PURPOSE OF PROCESSING PERSONAL DATA
The User’s Personal Data may be processed by the Administrator for the following purposes:
1. account registration and account management in the Service – based on acceptance of the terms and conditions of the Terms and Conditions – legal basis Article 6(1)(b) RODO,
2. fulfilling the Administrator’s legal obligations related to accounting, bookkeeping and taxes – legal basis Article 6(1)(c) RODO,
3. sending marketing information to the User via the Newsletter – based on the User’s voluntary consent – legal basis Article 6(1)(a) RODO and Article 6(1)(f) RODO,
4. conduct direct marketing of own products and services using profiling methods, including based on assessment of Users’ preferences, which is the Administrator’s legitimate interest – legal basis Article 6(1)(f) RODO,
5. communication with the Service User – which constitutes the Administrator’s legitimate interest – legal basis Article 6(1)(f) RODO,
6. investigating or defending against claims, which is the Administrator’s legitimate interest – legal basis Article 6(1)(f) RODO,
7. informing about job offers and collecting application documents as part of ongoing recruitment processes – legal basis Article 6(1)(b) RODO, taking actions that lead to the conclusion of a contract and based on the User’s consent – legal basis Article 6(1)(a) RODO,
8. adjusting and developing the functionality of the Service, including its structure and content tailored to the individual needs of Users, as well as maintaining the safety and quality of services provided by the Service with the use of technology collecting and processing data recorded in cookies, including through the use of mechanisms monitoring activity during use of the website – based on the legitimate interest of the Administrator and the consent of the User – legal basis Article 6 (1) (a) and (f) RODO,
9. to create an archive in the event of a need on the part of the Administrator to defend, establish or assert certain claims by Users or third parties – legal basis Article 6(1)(f) RODO,
10. conduct analytical and statistical activities using Anonymous Information for this purpose – legal basis Article 6(1)(f) RODO.
V. CATEGORIES OF PERSONAL DATA PROCESSED AND THE DESCRIPTION OF THEIR PROCESSING
1. The Administrator processes the User’s Personal Data related to the performance of the service provided electronically which consists in enabling registration and use of the tools of the Service and the optAd360 AI Engine system. The Administrator processes Personal Data such as: first name(s) and last name(s), e-mail address, telephone number, mailing address, country of origin, language in which you wish to be contacted. Provision of the above-mentioned Personal Data is necessary for the fulfillment of obligations under the concluded contract. In the absence of the above Personal Data the Administrator will not be able to create a user account.
2. To communicate with the User, the Administrator processes such Personal Data as: name, telephone number, e-mail address and the language in which the User would like to communicate with the Administrator. In addition, the Administrator also processes other Personal Data provided by Users in the content of their correspondence. Provision of the above Personal Data is voluntary, although necessary to establish contact with the Administrator and the later handling of correspondence by the Administrator. The Administrator indicates that due to the need to be able to prove certain facts in the future, it reserves the right to archive the history of correspondence conducted with a particular User. Therefore, the User may request the Administrator to provide him/her with the history of archived correspondence and its deletion.
3. To send marketing information, including commercial offers, via the Newsletter, the Administrator processes the following Personal Data of the User, name, and e-mail address. Provision of the above Personal Data is voluntary, although necessary to subscribe to the Newsletter. The User may at any time unsubscribe from further subscription to the Newsletter. To cancel the subscription, the User should click on the link visible in emails received from the Administrator or send an appropriate information about resignation from the subscription to the Administrator’s email address firstname.lastname@example.org.
4. To carry out direct marketing activities, the Administrator processes the User’s Personal Data such as information about the history of ordered and realized services, ways of using the Service and geolocation of the User.
5. To carry out the recruitment process, the Administrator processes the Personal Data of the candidates such as name and surname, date of birth, contact details, information about education, professional competencies and previous experience, and other data provided directly by the candidate in the application documents.
6. To optimize the Service and introduce new functionalities and support the optAd360 AI Engine system, the Administrator undertakes several analytical and statistical activities using Anonymous Information and cookies provided by certain tools such as Google Analytics. Due to the nature of Anonymous Information, the Administrator is not able to assign it to a particular User and thus is not able to provide the User with access to Anonymous Information.
7. In connection with the contract between the User and the Administrator for the provision of services by electronic means, the Administrator is obliged to fulfill its accounting and tax obligations, such as issuing invoices, including invoices in the Administrator’s accounting records and storing them. To issue an invoice, the Administrator processes such Personal Data of the User as name and surname, company, registered office address, Tax Registration Number, REGON number.
VI. DATA RETENTION PERIOD
1. The User’s Personal Data will be processed for the period during which the User has an active account on the Administrator’s Service and, after termination of the agreement for the provision of services by electronic means, for the periods required by law for the investigation or defense against possible claims, but no longer than for 6 years counted from the date of termination of the agreement for the provision of services by electronic means.
2. The User’s Personal Data processed in connection with the sending of marketing information will be processed until the User withdraws consent. However, the withdrawal of consent shall not affect the compliance of data processing performed before the consent was withdrawn.
3. The User’s Personal Data processed for direct marketing purposes will be processed for the duration of the purpose for which they were collected, but no longer than until an objection is made to the processing of the Personal Data.
4. The User’s Personal Data processed for the recruitment process will be processed until the candidate is selected for the position specified in the advertisement. In the case of consent to leave application documents for the purposes of future recruitment processes, the Personal Data will be stored for 12 months counted from the date of the given candidate’s consent to its further processing for the purposes of future recruitment.
5. The User’s Personal Data processed for the purpose of communication and handling of correspondence will be processed until the communication with the User is terminated unless it is necessary to archive it to show the history of correspondence in the future. In such cases, the Administrator is not able to explicitly determine for what period the correspondence will be archived.
6. The User’s Personal Data processed for the purpose of sending marketing information through the Newsletter will be processed until the User unsubscribes from the Newsletter or until the Administrator cancels further Newsletter. At the same time, the Administrator indicates that the User’s Personal Data may also be processed after unsubscribing from the Newsletter, if the processing will be necessary to defend against claims related to the sending of the Newsletter to the User. For proof of certain facts by the Administrator in the future.
7. The User’s Personal Data processed in connection with the fulfillment of the Administrator’s tax and accounting obligations will be processed for the period indicated in the provisions of the law, in particular the Law on Accounting and Tax Coordination.
8. The User’s Personal Data processed in connection with the establishment, assertion and defense of claims shall be processed by the Administrator until the expiration of the statute of limitations for specific claims, whereby the period of limitations for claims may vary in accordance with applicable law.
9. The User’s Personal Data related to the archive created by the Administrator will be processed until it is no longer useful.
VII. RECIPIENTS OF PERSONAL DATA
1. The User’s Personal Data may be disclosed to:
A. the hosting provider on whose server the User’s Personal Data is stored,
B. to online payment operators (such as PayPal, TransferWise, Payoneer or Bank Transfer),
C. entities providing legal services related to the Administrator’s operations,
D. entities providing IT services related to the Administrator’s operations,
E. entities other than those indicated above that are authorized by law to obtain from the Administrator information related to the Administrator’s business, which may also include Personal Data,
F. subcontractors, in particular entities that provide and operate selected IT systems and solutions, those that enable User profiling,
G. entities providing accounting and bookkeeping services to the Administrator. In addition, to the necessary extent for the implementation of tax and accounting obligations, User Personal Data may also be transferred to tax authorities. In addition, User Personal Data may be made disclosed to authorities or institutions authorized to access the data under the law such as courts, prosecutors’ offices, police services and security services,
H. to Optad360 sp. z o.o. with its registered office in Wrocław, 76 Braci Gierymskich Street, 51-640 Wrocław, entered in the Register of Entrepreneurs under KRS number: 0000546171, REGON number: 36091371800000, holding the Tax Registration Number: 7010471176. The entrustment of Personal Data is based on an executed personal data entrustment agreement. The entrustment is necessary due to optad360’s assistance in achieving the objectives of Publishers Revenue Optimization as indicated in Section VI. The categories of Personal Data processed under the entrustment include those indicated in Chapter V. Data shall be processed for the period indicated in Chapter VI.
2. The User’s Personal Data may be transferred outside the European Economic Area. In connection with the Administrator’s use of the tools provided by entities storing Personal Data on servers located in the territory of third countries, including the USA. The transfer of User Personal Data shall be made based on standard data protection clauses adopted by the European Commission, providing adequate safeguards for the protection of privacy and the rights and freedoms of the data subjects.
VIII. INFORMATION ABOUT USER RIGHTS
1. The User has the following rights in connection with the Administrator’s processing of his/her Personal Data:
A. Right of access to Personal Data – User is entitled to obtain confirmation from the Administrator whether your Personal Data is being processed and, if so, you have the right to access information regarding its processing, in particular information about the purpose of processing and the category of Personal Data processed. The User is also entitled to request a copy of the processed Personal Data.
B. Right to rectify processed Personal Data – the User has the right to correct false Personal Data. In addition, the User also has the right to request the replacement, completion, or deletion of erroneous or misleading information regarding his/her Personal Data.
C. Right to erasure of the User’s Personal Data (the right to be forgotten) – the User has this right only if the right to delete Personal Data is exercised and only in situations where the Administrator has no other legal basis for further processing.
D. Right to restrict the processing of Personal Data to a specific purpose – if, in the opinion of the User, his or her Personal Data is processed by the Administrator in an inaccurate or unreasonable manner, the User may request that the processing of his or her Personal Data be restricted only to storage or performance of activities agreed upon with the User.
E. Right to portability Personal Data – the User has the right to receive in a structured, commonly used format the Personal Data provided to the Administrator. In addition, he has the right to send the received data to another Administrator. The User also has the right to request that his/her Personal Data be sent by the Administrator directly to another administrator, if technically possible.
F. Right to object – the User has the right to object to the Personal Data processed by the Administrator based on the Administrator’s legitimate interests.
G. Withdrawal of consent for processing of Personal Data – at any time the User has the right to withdraw the consent he/she has given for the processing of your Personal Data. However, the withdrawal of consent does not affect the lawfulness of the processing of Personal Data prior to the withdrawal of consent.
H. Right to lodge a complaint with the competent supervisory authority – the User may lodge a complaint with the President of the Office for Personal Data Protection (address: President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw) if he/she considers that the Administrator is processing Personal Data in a manner inconsistent with the applicable laws. If the User would like to exercise the above-described rights, he/she is obliged to contact the Administrator in writing at the Administrator’s registered office address or via e-mail: email@example.com.
IX. INFORMATION ABOUT AUTOMATED DECISION-MAKING, INCLUDING PROFILING
The User’s Personal Data will be profiled to adjust the Administrator’s marketing activities to your individual needs and preferences.
X. SECURITY OF PERSONAL DATA
The Administrator uses appropriately selected organizational and technical measures aimed at ensuring certain security standards for the Personal Data processed. To protect Personal Data, the Administrator uses certain systems and procedures aimed at securing the processed Personal Data from disclosure to unauthorized persons. In addition, the Personal Data acquired by the Administrator is stored in computer systems to which access is strictly limited.
XI. COOKIES POLICY
1. Types of Cookies that are used:
A. The Cookies used by the Administrator are safe for User Devices. This means that it is not possible for viruses or other unwanted software or malware to enter the Users’ Devices. These Cookies allow̨ to identify the software used by the User and customize the Service individually for each User. Cookies usually contain the name of the domain from which they originate, the time they are stored on the Device and the assigned value.
B. Due to the necessity to provide the service, the Administrator uses 3 types of Cookies:
- Necessary – absolutely required for the proper functioning of the website or functionalities the User wants to use.
- Analytical (also called statistical) – collect information about how often the website is visited and how it is used. This aggregated and anonymous information is used to improve the content and performance of the site – without consent this is not possible.
- Advertising (also known as marketing) – allows us to display ads matched to the profile of the user visiting the site. Profiles are built based on browsing history, which are shared with advertising partners so that personalized ads are displayed on other sites.
C. For how long Cookies will be placed on the User’s terminal Device:
- Session – (temporary), remain in the memory of the User’s browser until they leave the optad360.com website. Session cookies are mandatory for the correct operation of the selected applications and the correct display of the website content. The mechanism of session cookies does not allow to collect any Personal Data or any confidential information from the User’s Device.
- Permanent – used to make the site more attractive to the User. They are responsible for remembering the User’s preferences during using the site and for displaying personalized advertisements. Permanent cookies are not deleted when the website is closed and are stored on the User’s Device between sessions. The mechanism of persistent cookies does not allow the collection of any Personal Data or any confidential information from the User’s Device.
D. The User may restrict or disable access of Cookies to your Device. If the User restricts or disables Cookies, use of the Service will be deprived of functions that by their nature require Cookies, including the optAd360 CMP tool.
E. Cookies used on “optad360.com” include:
- File “_ga” – allows the service to distinguish between individual Users and lasts for 2 years. The “_ga” file is used by all sites that use Google Analytics (including Google services). Each “_ga” file is unique to a specific service, so it cannot be used to track a User or browser on other, unrelated sites.
- The file “_gat” – file makes it possible to distinguish between Users.
- The file “_gid” – enables the collection of internal information about the User’s activity to improve the experience of using the site.
- The file “optad360_cookies_consent” – enables identification of User’s consents given (or not given) to display ads tailored to User’s preferences based on User’s behavior on the site.
2. Purposes for which Cookies are used:
A. Service configuration:
- adapting the content of the Service’s pages to the User’s preferences and optimizing the use of the Service’s pages,
- recognition of the Service User’s Device and its location and, accordingly, display of the website, adapted to his/her individual needs,
- to facilitate browsing of the website’s resources on subsequent visits,
- to remember settings selected by the User and personalize the User’s interface, e.g., with respect to the User’s chosen language or region of origin.
B. Authorization of the User on the Service:
- to ensure the security of the provision of services electronically, including the maintenance of the session of the User of the Service after logging in and the recognition of the user at the next session,
- correct configuration of selected functions of the Service, allowing verification of authenticity of a browser session,
- optimizing and increasing the efficiency of services provided by the Administrator.
C. execution of processes necessary for the full functionality of the websites, including the creation of statistics to improve the functionality of the structure and content of the Service,
D. execution of analysis and research, as well as audience audit – creation of anonymous statistics, helping to understand how the Users of the Service use the websites of the Service, which allows to improve their structure and content,
E. The Administrator uses External cookies for the following purposes: collection of general and anonymous statistical data through analytical tools – Google Analytics [cookie administrator: Google Inc. based in the USA],
- storing information on or accessing your Device,
- selecting basic ads,
- creating a profile of personalized ads,
- selecting personalized ads,
- creating a profile of personalized content,
- selection of personalized content,
- measuring ad performance,
- measuring content performance,
- applying market research to generate audience feedback,
- developing and improving products.
The product offered by the Administrator (optaAd360 CMP) complies with the requirements of the TCF 2.0 (Transparency and Consent Framework) standard.
3. Possibilities to determine the conditions for storing or accessing by Cookies:
A. the default settings of browsers allow the storage of Cookies,
B. the User may at any time change the settings for Cookies independently, specifying the conditions for their storage and access by Cookies to the User’s Device,
C. changes in the settings of Cookies, the User can make using the settings of the Internet browser (commonly used: Mozilla Firefox, Internet Explorer, Google Chrome, Opera, Safari) or using̨ the configuration of the service. These settings can̨ be changed so that they block the automatic handling of Cookies in the settings of the web browser or inform about each time Cookies are placed on the User’s Device,
D. specific information about the possibility and methods of handling cookies is available in the settings of your software (web browser),
E. the User may delete cookies at any time using available functions in the web browser,
F. restricting or disabling Cookies, may affect some of the functionality available on the Service,
G. Cookies stored on the User’s end Device may be used by trusted entities cooperating with the Administrator,
H. in the optAd360 CMP tool, the user can personalize the settings relating to Cookies.
4. Tools offered by the Administrator:
- optAd360 CMP (Consent Management Platform) – a tool that manages users’ consents to the use of their personal information for personalized ad impressions. The tool includes a list of advertising providers to whom information stored in Cookies is transmitted, so users can check who they allow to use their information. The CMP is required for all websites with European Union audiences and is required by all providers of programmatic technology solutions. optAd360 CMP is certified by IAB Europe, demonstrating compliance with the Transparency & Consent Framework v2.0. With the IAB certification of the tool as a Consent Management Platform Service, the User is assured that the tool meets the requirements necessary for the Administrator to make it available to third parties.
B. Other tools offered by the Administrator:
- optAd360 AI Engine – processing of Personal Data and Cookies is not present in the indicated product. The owner of the indicated product is optAd360, which is the processor for the Administrator. If you have any questions, please contact the Administrator.
- Revenue Booster – processing of Personal Data and Cookies does not occur in the indicated product. If you have any questions, please contact the Administrator.
- Recovery Tool – processing of Personal Data and Cookies is not present in the indicated product. If you have any questions, please contact the Administrator.
- Ad Mapper – processing of Personal Data and Cookies does not occur in the indicated product. If you have any questions, please contact the Administrator.
- Ad Revenue Index – processing of Personal Data and Cookies does not occur in the indicated product. If you have any questions, please contact the Administrator.
- Ad Gallery – processing of Personal Data and Cookies does not occur in the indicated product. If you have any questions, please contact the Administrator.
XII. FINAL PROVISIONS