Publishers Revenue Optimization sp. z o.o. (optad360.com)
I. THE CONTROLLER
The Controller of your personal data is Revenue Optimization sp. z o.o. (the owner of optad360.com website) located in Wrocław at Braci Gierymskich 76 Street, 51-640 Wrocław, Poland entered into the register of entrepreneurs kept by the District Court, KRS 0000520454, NIP 894-30-54-999, share capital 6 000 zł.
The Controller’s contact details
Address: Publishers Revenue Optimization sp. z o.o. Braci Gierymskich 76 Street, 51-640 Wrocław, Poland
II. GENERAL INFORMATION
We make every effort to protect the interest of data subjects. We ensure that the data we collected are:
A. processed lawfully,
B. collected for specific, lawful purposes and not further processed contrary to these purposes,
C. adequate to the purposes for which they are processed,
D. stored no longer than it is necessary for the purposes of processing.
1. The Controller – Publishers Revenue Optimization sp. z o.o. located at Braci Gierymskich 76 Street, 51-640 Wrocław, Poland which stores and acquires access to information on the User’s devices via cookie files.
2. Cookies – IT data, particularly, small text files saved and stored on devices, thanks to which the User uses the Website.
3. The Controller’s cookies – Cookies placed by the Controller, related to running the Website by the Controller,
4. Device – an electronic device through which the User accesses the Website.
5. External cookies – Cookies placed by the Controller’s partners through the Website.
6. GDPR is Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
7. Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
8. Personal data processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
9. Profiling means any form of automated processing of personal data, which consists in the use of personal data to evaluate certain personal factors of a natural person, in particular to analyze or forecast aspects related to the effects of a natural person’s work, economic situation, health, personal preferences, interests, reliability, behavior, location or movement.
10. User – a physical person using a Website
11. Website – an Internet site or application where the Controller runs a service, under the domain optad360.com.
IV. THE PURPOSE OF PROCESSING YOUR PERSONAL DATA
Your personal data may be processed for the following purposes:
1. registration your account on the Website and its management – based on the acceptance of the conditions of the ToS (article 6, section 1, point b GDPR)
2. when processing is necessary for compliance with a legal obligation to which the controller is subject, regarding accounting, taxes and for archival purposes – based on article 6, section 1, point c GDPR)
3. sending you marketing information, i.e. the newsletter – based on your consent (6, section 1, point a GDPR)
4. conduct direct marketing of own products and services using profiling methods, including on the basis of the assessment of Users’ preferences, which is almost a justified interest of the Administrator (6, section 1, point f GDPR)
5. communication with the website’s User – which constitutes the Controller’s justified interest (6, section 1, point f GDPR)
6. pursuing or protecting from claims, which constitutes the Controller’s justified interest (6, section 1, point f GDPR)
7. informing you about recruitment processes – based on article 6, section 1, point b GDPR, i.e. taking actions leading to making an agreement and based on your agreement (article 6, section 1, point a GDPR)
8. adjusting and developing the website’s functionalities, including its structure and contents, to Users’ individual behaviors and keeping safety and quality of service provided by the Website using technology that collects and processes data saved in cookie files – based on the Controller’s justified interest (6, section 1, points a and f GDPR).
V. PERSONAL DATA THAT ARE PROCESSED
1. Publishers Revenue Optimization processes mostly your personal data connected with carrying out the electronic service enabling you to register on the Website, including in particular: name(s) and surname(s), email address, telephone number, correspondence address, language for contact. Providing these data is a conventional requirement and you are obligated to provide them. If you do not provide them, Publishers Revenue Optimization will not be able to create your account.
2. For purposes related to communication, Publishers Revenue Optimization processes mostly names and surnames, phone numbers, e-mail addresses and your contact language. Providing these data is voluntary and you can refuse to provide them, however, we will not be able to reply to your questions.
3. For purposes relating to sending marketing information, including commercial offer, Publishers Revenue Optimization processes your e-mail address and phone number.
4. For purposes related to direct marketing activities, including information about the history of ordered and provided services, the manner of using the Website or geolocation.
5. For purposes relating to an ongoing recruitment process, Publishers Revenue Optimization processes mostly your name and surname, date of birth, contact details, education information, professional qualifications and experience, and other data provided by you directly in application documents.
VI. PERIOD OF STORING DATA
1. Your personal data will be processed for the period when you are an active user of the Website, and after that, for a period necessary to keep compliance with the provisions of law, pursue or protect from possible claims, however, no longer than 6 years counted from the day of terminating the agreement on providing services in electronic form.
2. Data processed for sending marketing information will be processed until you withdraw your consent with the reservation that such withdrawal does not influence the lawfulness of the processing that was done before it.
3. The data processed for the purposes of direct marketing will be used for the duration of the purpose for which they were collected, but no longer than until the objection to such processing is submitted.
4. Data processed for the recruitment process will be processed until the candidate for a specific position is selected. If you agree to leave your application documents for future recruitment processes, your data will be stored for 12 months counted from the day you agreed to it.
VII. PERSONAL DATA RECIPIENTS
1. Your personal data may be revealed to:
A. Internet payment operators (such as PayPal, TransferWise, Payoneer, or Bank Transfer),
B. subjects providing services connected with Publishers Revenue Optimization’s business,
C. subjects providing IT services connected with Publishers Revenue Optimization’s business,
D. subjects other than the ones mentioned above which are legally authorized to receive information from Publishers Revenue Optimization about its operations, which may include your personal data,
E. sub-contractors, particularly, subjects providing and maintaining selected IT systems and solutions, in particular enabling User profiling.
2. Your personal data may be shared outside the European Economic Area based on standard data protection clauses accepted by the European Commission, which therefore are subject to appropriate protection measures in the area of protection of privacy and rights and freedoms of data subjects.
VIII. INFORMATION ABOUT YOUR RIGHTS
1.You have the right, in particular, to:
A. get access to the contents of your personal data processed by the Controller,
B. rectify your data,
C. remove your data,
D. limit the processing of your data,
E. transfer your data,
F. object to the processing done based on the Controller’s legally justified interest,
G. withdraw your consent at any moment, not influencing the legality of the processing done before it.
2. You have the right to make a complaint to the President of the Personal Data Protection Office when you think that the processing infringes on your rights or freedoms, especially those resulting from the GDPR.
3. If you voluntarily agree to your data to be processed, you have the right to withdraw this agreement.
IX. INFORMATION ABOUT AUTOMATED DECISION-MAKING, INCLUDING PROFILING
1. Your data will be profiled in order to adapt the Administrator’s marketing activities to your individual needs and preferences.
X. COOKIES POLICY
1. Types of Cookies used
A. Cookies used by the Controller are safe for the User’s Device. Importantly, by this way, it is not possible to transmit any malicious or unwanted software to the User’s Device. Such files enable Users to identify software used by the User and adjust the Website individually to every User. Cookies usually contain the name of the domain that they come from, and time they are stored on the Device has a value.
B. Regarding the necessity for Publishers Revenue Optimization sp. z o.o. to provide the service by, 3 cookie file types are used:
- Necessary – essential for the Website to function properly or functionalities that the User wants to use. Stored on the Device for one day.
- Analytical – a.k.a. statistical – they collect information about how much a Website is visited and how it is used. This aggregated and anonymous information serve to improve the content and performance of the Website – without the agreement it is not possible. They are stored on the Device for two years.
- Advertising – a.k.a. marketing – let display advertisements adjusted to the User’s profile. Based on their history of browsing, profiles are built and shared with advertising partners in order for personalized advertisements to be displayed on different websites. They are stored for three months.
C. Regarding the time for which cookie files are stored on the end-user’s Device:
- Serial – temporary which remain in the User browser’s memory until leaving the optad360.com Website – they are necessary for proper functioning of selected applications and displaying the content of the site. The serial Cookies’ mechanism does not allow them to download any personal data or any confidential information from the User’s Device.
- Permanent – used to make the Website more attractive to the User, among others, to save their preferences while using the website or to display personalized advertisements, they are not deleted after closing and are stored on the User’s Device between sessions. The mechanism of permanent Cookies does not allow them to download any personal data or any other confidential information from the User’s Device.
D. The User has an option to limit or disable the Cookies’ access to their Device. In this case, they can use the Website apart from the functions that inherently require cookie files.
2. What purposes Cookies are used for
A. Configuration of the Website:
- adjusting the contents of pages of the Website to the preferences of the User and optimizing using them;
- recognizing the User’s Device and their location and appropriately displaying the Website;
- facilitating visiting the Website’s content in future visits;
- saving settings used by the User and personalizing their interface, e.g. regarding their chosen language or region.
B. Authenticating the User in the Website:
- ensuring the safety of provision of services in electronic form, including storing the Website’s User’s session after their logging in and recognizing the person visiting on the next session,
- appropriate configuration of selected functions of the Website, in particular, enabling to verify their browser session authenticity,
- optimizing and making the services provided by the Controller more efficient;
C. Carrying out processes necessary for full functionality of Websites, including creating aggregated statistics which serve to improve functionalities of the Website, its structure and contents;
D. Analyzing and research and auditing of viewability – creating anonymous statistics which help understand how the Website’s Users use it, which enables to improve their structure and contents;
E. The Controller uses external Cookies for the following purposes: collecting general and anonymous static data through analytical tools – Google Analytics [the Cookies’ Controller: Google, Inc. located in the USA].
3. Options to determine the conditions of storing or accessing through Cookies
A. Default settings of browsers allow you to store cookie files.
B. The User can individually and at all times change the settings of cookie files, determining the conditions of storing them and access that cookie files have to the User’s Device.
C. Changes in settings mentioned above, can be made by the User with the settings of a browser (commonly used: Mozilla Firefox, Internet Explorer, Google Chrome, Opera, Safari) or with configuration of the service. These settings may be changed particularly in a way to block automated handling of cookie files in the settings of an Internet browser or inform about their placing on the Device every time.
D. Detailed information about the options and ways of handling cookie files are available in the software settings.
E. The User can at any moment remove cookie files from available functions in the Internet browser they use.
F. Limiting of using or blocking cookie files may influence some functionalities available on the Website.
G. Cookie files stored on the User’s end-device may be used by trusted subjects cooperating with Publishers Revenue Optimization sp. z o.o.
XI. FINAL PROVISIONS