Last updated: April 17, 2018
- If you are a Customer
2.1 Information we Collect About Customers
2.2 How we Use Customer Information?
2.3 Sharing Customer Information
2.4 Your Choices
- If you are an End User
3.1 Information we Collect About End Users
3.2 How We Collect End User Information
3.3 Sharing or Disclosing User Information
3.4 How do we use User Information
3.5 Users’ Choices
3.6 Information Security
3.7 Data Retention
3.8 Cross-Border Data Transmission
3.9 Children’s Privacy
3.10 Comments and Questions
When we use the term "Personal Information" we mean information that may be used, either alone or in combination with other information, to personally identify an individual (natural person), such as a first and last name, an email address, phone number, a home or other physical address, and other contact information. In some jurisdictions and given the specific use we make with the information, IP address that your Internet service provider allocates for your device, may also be considered as Personal Information (in the European Union for example). In which case, we will be treating the information as personal in all handling and safeguarding aspects, however, DoableMedia do not make any use of such information for identification or personalization purposes and we do not combine such data with another in attempt to identify you.
2. IF YOU ARE A CUSTOMER
If you are a Customer of the Services, in addition to the User Information we collect, we may collect Personal Information that you are required to submit to us when you open an account with us, for purposes of engaging with us in a business relationship or to otherwise integrate our Services into your own sites, products, software and services. In which case, our data collection practices will be as follows:
a. Information we Collect About Customers
In addition to information we may collect about End Users, (as detailed below), if you are a Customer and you choose to open an account with us, you will be asked to submit certain Personally Identifiable Information, such as first and last name, email address of the entity on which behalf you are engaging with us and chosen password for accessing your account. We will also collect other Information that Customers choose to provide to us, such as the contents of a message that a Customer submits through our Website (collectively “Customer Information”).
b. How we Use Customer Information?
We use Customer information in order to (i) render our Services and contact Customers that express their will to communicate with us and/or engage with the Services; (ii) communicate with Customers and respond to any inquiry or any other form of communications from Customers; (iii) Services providers, agents, contractors, vendors and other individuals or entities which requires access to Customer Information in order to perform their functions;
c. Sharing Customer Information
We may disclose or share Customer Information to a current or future (i) affiliate, parent companies and/or subsidiaries that help us with facilitating the Services or operating the Website; (ii) services providers, agents, contractors, vendors and any other individual or entity which requires access to Customer Information in order to perform their functions; (iii) other Customers, to the extent required to render the Services and consented by Customer.
d. Your Choices
As a Customer of us, you have certain rights concerning your Customer Information, including: edit, correct, verify, update or delete your Customer Information. If you wish to exercise any of those rights, you may do so by contacting us directly at: firstname.lastname@example.org. In addition, any email communication we send to you, will include an opt-out / unsubscribe option that you can directly exercise via the email communication. Please note that if you choose to unsubscribe from email communication, we may still hold your account information and Customer Information and may contact you for updates regarding your use if the Services or any other relevant account information.
3. IF YOU ARE AN END USER
a. Information we Collect About End Users
When you visit the Site or access, interact or engage with any of the Platforms, we may collect some information about such use as dependence of the type of Platform (and respective technology) with which you interact. Such information generally includes the following, and may be attributed to our Platform or Service ID that we generate for each type of Platform or to a general user ID that we generate for each user on the system and is a completely random identifier: device information (such as type, operating system type, version and language), your user agent, that includes the browser type, version and language from which you access the Platform or consume the Services, the domain or URL of the website you browse in which the Platform is integrated and the Services are displayed or served; in which case, we do not store such URL, but our system will only use it on real time to make a decision about the type of content to display to you. We may also collect the IP address of the device that accessed to the Services for purposes of bot or real End User validation and fraud detection, in which case such data is retained separately from other data items with no ability to correlate the IP address with other data (“User Information”). User Information and Customer Information will be jointly referred to as “Information”.
b. How We Collect End User Information
We, or advertisers partners, may use standard Internet technology such as web beacons (or "clear gifs"), tracking pixels, and other similar technologies, to gather analytics, anonymous, aggregate, non-personally identifiable information about End Users that interact with the Platform or the content that is available on top. Please be aware, as a Platform, we tend to host third party content, features, elements and services that are not necessarily provided by us (“Third Party Content”). Such Third Party Content may include graphics, animation, video, ads, offers, links, buttons or any their similar feature with which you may engage. Any interaction you make with such Third Party Feature is govern by their providers’ policies, terms and conditions, so we advise you to refer to their privacy policies to learn more about their data collection and protection practices.
iii. Log Files.
Technical information from your browser is automatically collected into a log file, when a you visit our Site or interact with any of the Platforms. This information includes your device’s IP address, User’s browser type, operating system, access times, the content of any undeleted cookies that the End User’s browser previously accepted from us, and the referring website address.
For more information please review our detailed Cookies Policy.
c. Sharing or Disclosing User Information
We do not share Personal Information about you with Third Parties, except for the following circumstances:
i. We pass along a page URL in which our Services are implemented and pass it along to our third-party content and advertising partners, so they will be able to bid for a content that best suit such web-page.
ii. Anti-fraud purposes where a third-party monitoring body or certifier of such third is require to maintain and audit a black list of IP addresses.
iv. Enforcement. We may share your Information with any third party if we believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce our terms and conditions, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of our Platform, system network or technology, our affiliated entities, our users, yourself, and/or the public.
v. Third Party Partners. In some cases when we buy media online, we may submit non-personal information that is cookie based. In those cases, non-personal parameter we provide to the media owner, may become personally identifiable when such media owner combines our parameters with its own existed information about you, to which you gave your consent when first interacting with such media owner’s services (for example social media platforms).
vi. Merger, Sale or Bankruptcy. In the event that we or one of our affiliated entities is acquired by, or merged with, a third party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In such case, we will require the acquiring entity to post its data practices and provide you with any of your rights as per the jurisdiction of your residency.
vii. Other Third Parties. We may send or otherwise share User Information to/with various third parties that help us with our business operations (for example, customer service operators and email administration providers, where applicable and made available), that help us understand how our users use the Site and Services, operate them and to improve them. These third parties may have their own privacy policies that they adhere to, and we require them to make it available whenever their services are provided. We recommend you revisit such privacy policies when those Third Parties render their services directly to you. Also, these third parties may be based (and their servers may be located) anywhere in the world.
d. How do we use User Information
Please note that we use User Information for purposes of operating the Platforms, providing the Services and constantly improve them. That includes the following uses:
i. Operating and further developing and improving the Services;
ii. For counting and tracking purposes when the Platform involves ad serving and campaign management;
iii. Validation of users as humans and anti-fraud monitoring;
iv. Where you provided us with your email address, for example if you contact with us for an inquiry or request, we will use your contact details and inquiry content to process it and respond and other communications with you;
v. Identify or authenticate your access and use of your account (in case of a Customer Information).
vi. For any legally permissible purpose in our sole discretion or law enforcement requirement;
e. Users’ Choices
i. Cookies and web tracking technologies.
you may set your browser to refuse and/or block any cookies from us or third party services, or periodically remove and delete any existing cookie installed. Be aware that in such cases some of the Services’ functionalities would not be properly available.
ii. Opt-out (End Users).
iii. California Privacy Rights.
California Civil Code Section 1798.83 permits our Customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are an End User, to date, we do not collect any Personal Information that may identify you so we would not be able to exercise this right. If you are a Customer you may sending an email to: email@example.com.
iv. EU Data Subject Rights.
If you are a residence of Canada, you are permitted to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, where applicable. To make such a request, please send an email to firstname.lastname@example.org.
If otherwise you have any question about your Personal Information you may contact our compliance team at: email@example.com.
f. Information Security
We, and third party services/affiliate entities implement data security systems and procedures to secure the information transmitted, processed and stored in our computer servers and systems. For example, the Site is encrypted by using SSL and so as any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the world-wide network. Therefore, we cannot guarantee that the Services and our servers are immune to unauthorized access to the information stored therein and to other information security risks. If you have any questions about our security and safeguards efforts, you can contact us at: firstname.lastname@example.org.
g. Data Retention
Unless we are instructed otherwise by applicable laws, we retain Information we collect for as long as needed to provide the Services, operate them, monitor them, and to comply with our legal obligations, resolve disputes and enforce our agreements.
h. Cross-Border Data Transmission
i. Children’s Privacy
The Services are not designed to attract children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16. If we learn that we have collected Personal Information from a child under 16, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us in accordance to the contact information set forth below.
j. Comments and Questions