We at Five Media Marketing Limited d/b/a GeoEdge (“GeoEdge” “us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice describes the types of information we collect from you when you visit and/or use our website and/or mobile application (“Site” or “App”, accordingly) and/or our services (“Services”). This Privacy Notice also explains how we may process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://www.geoedgejp.wpengine.com/terms and https://publisher.geoedge.com/terms (“Terms”).

GeoEdge is the data controller in respect of certain processing activities outlined in this Privacy Notice. Our registered office is 7 Florinis St., Nicosia 1065, Cyprus and our registration number 158772. GeoEdge is the data processor in respect of processing activities preformed of behalf of its customers. Information may also be collected by additional data controllers as listed below.

“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.

PRIVACY NOTICE KEY POINTS

The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.

THIS PRIVACY POLICY ONLY APPLIES TO GEOEDGE

This policy does not apply to the practices of companies that GeoEdge does not own or control, or to people that GeoEdge does not employ or manage. GeoEdge can be used to browse other sites on the Internet. Each site may have their own privacy policy and GeoEdge cannot be responsible for any information you provide to these sites when accessing them through GeoEdge. GeoEdge is not responsible for the security practices of the Web sites that you access through our site or through GeoEdge’s solutions.

• Personal Data We Collect. When you register, we collect Personal Data provided by you, such as your name, email address, phone number and the company you work for. If you use the Services by logging in through LinkedIn and/or any other third-party login service, we may also receive Personal Information about you as provided by LinkedIn and/or any other third-party login service. We also (automatically) collect information about your use of the App and/or Site and/or Services, such as your IP address and operating system when you use our proxy toolbar. If you contact us for questions or complaints, we will collect the information related to your inquiry.
• How We Use the Information We Collect. We use the information (including Personal Data) we collect mainly to administer and provide the App and/or Site and Services, contact you with administrative information, contact you with marketing offers , and improve the App, Site and Services. We may combine the Personal Data collected by us with data (including Personal Data) received from third parties, including for marketing purposes.
• Basis for Processing Your Personal Data. Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you. Processing the information for third-party marketing purposes may be based upon your consent, as may be required under applicable law. Processing for the purposes of developing and enhancing new features and our products and services, for analytics and usage analysis, for the marketing of our services, fraud prevention and for security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
• Sharing the Personal Data We Collect. We may share the Personal Data we collect with our subsidiaries and our service providers and subcontractors who assist us in the operation of the App and/or Site and process the information on our behalf and under our instructions.
• International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Data. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
• Your Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Data and obtain a copy of the Personal Data we have collected about you. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. You also have the right to object at any time to processing your personal data for marketing purposes. To exercise any of your rights, please contact us as specified below.
• Use of Cookies and Similar Technologies. We use cookies and similar technologies to help personalize your experience by helping save your settings and customizations across visits and providing you targeted content and advertisements matching your interests, which we have identified based on your activity and browsing history on the App and/or Site. You can adjust your settings to determine which cookies you do or do not allow. Changing your settings and/or deleting existing cookies may affect the Services or prevent the provision of the Services.
• Retention. We retain information for as long as necessary for the purposes set forth in this Privacy Notice. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether those purposes can be achieved through other means, as well as applicable legal requirements.
• Security. We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Data, but they do not provide absolute data security.
• Children. We do not knowingly collect personally-identifiable information from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
• Third-Party Applications and Services. All use of third-party applications or services is at your own risk and subject to such third party’s privacy policies.
• Communications. Subject to your consent and applicable law, we may send you e-mail or other messages about us or our Services. You can stop receiving future communications from us by following the UNSUBSCRIBE link located at the bottom of each communication, by emailing us at [email protected].

PERSONAL DATA WE COLLECT

We collect information from you when you choose to use our App, Site and/or Services. In order to use our App, Site and/or receive related Services, you will be required to register and provide us with certain Personal Data. We also collect Personal Data when you make use of the App and/or Site, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason. If you use the Services by logging in through LinkedIn and/or any other third-party login service, we may also receive Personal Information about you as provided by LinkedIn and/or any other third-party login service. Please check such third-party’s policies in order to understand what information we receive.

Examples of the Personal Data that we collect from you when you register an account with us may include your name, phone number, e-mail address, company name and the last four (4) digits of your credit card number. Such Personal Data may be collected by us through the App and/or Site.

Additional types of Personal Data we may collect is subject to the type of Service you are using:

• In our Ad Verification service, which includes SpecHub solution and Real Time Blocking enhancement, we do not collect any additional Personal Data.

In our Proxy Toolbar we collect the IP address, geo location and operational system of our users.

When you use the App and/or Site, certain information may be automatically gathered about your computer or mobile device, such as operating system, IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any information regarding your viewing and purchase history on our App and/or Platform. It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information we may not be able to register you to the App, Site and/or provide you with the Services.

HOW WE USE YOUR PERSONAL DATA

General

We and any of our trusted third-party subcontractors and service providers may use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Site, App and Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to provide you with advertising on other third-party sites or apps you may visit, or via e-mail; (5) to contact you with informational newsletters and promotional materials relating to our App, Site and/or Services. We may combine the Personal Data collected by us with data (including Personal Data) received from third parties, including for marketing purposes; (6) to review the usage and operations of our App, Site and/or Services; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our App, Site and/or Services, and address any problems with the App, Site and/or Services and (9) to provide customer support.

Statistical Information

By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information“). Statistical Information helps understand trends and customer-needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

Analytics

We, or our service providers or subcontractors, may use analytics tools (“Tools“), including “Google Analytics” to collect information about the use of the App and/or Site and/or Services. Such Tools collect information such as how often users visit the App and/or Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the App and/or Site. The Tools may collect certain Personal Data, and may link such Personal Data to specific information stored in our customer database. We use the information we get from the Tools to improve our App, Site and Services. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use located at https://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at https://www.google.com/policies/privacy/.

Legal Uses

We may use your Personal Data as required or permitted by any applicable law.

BASIS FOR PROCESSING YOUR PERSONAL DATA

Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you, including responding to your inquiries or requests, contacting and communicating with you and providing customer support. When you make a purchase, sign up for our Services or engage in a transaction with us, we may also process your Personal Data to perform that contract.

Processing for the purposes of analytics and usage analysis, for fraud detection and prevention, for our recordkeeping and protection of our legal rights, compliance with legal and regulatory requirements, marketing of our products, network and information security, and product development and enhancements – are all necessary for the purposes of legitimate interests that we pursue. In conducting such processing activities, we balance these legitimate interests against the rights and interests of our users. If you would like more information regarding how we make such determinations, please contact us through the contact information specified below.

DISCLOSURE OF INFORMATION

We may share your information, including Personal Data, as follows:

Business Partners, Service Providers, Affiliates, and Subcontractors

We may disclose information, including Personal Data we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to (1) help us provide you with the Site and/or App and/or Services; (2) aid in their understanding of how users are using our App and/or Site and Services; (3) subject to your consent as may be required under applicable law, provide to you targeted offers and advertising on both our App and/or Site, as well as on other apps, platform and sites you choose to visit.

International Transfer

We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them information we receive (including Personal Data). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate penalties and effective remedies in the event of the violation of your data protection rights in such third country. You hereby consent to such international transfer.

Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us through the contact information listed below if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA. You hereby consent to such international transfer described above.

Business Transfer

We may transfer our databases containing your Personal Data if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Data, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.

Law Enforcement Related Disclosure

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Data as specified herein by emailing us at [email protected].

Other Uses or Transfer of Your Information

We allow you to use our App and/or Site and Services in connection with third-party services, sites, and/or mobile applications. If you use our App and/or Site and/or Services with or through such third parties, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third parties outside of our App and/or Site and/or Services, their own terms and privacy policies will govern your use of those services.

HOW WE PROTECT INFORMATION

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it, including by implementing the below:

Safeguards– The physical, electronic, and procedural safeguards we employ to protect your data include secure servers, firewalls, antivirus and SSL encryption of data.

Access Control– we dedicate efforts for proper management of system entries and limit access only to authorized personnel on a need to know on the basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.

Internal Policies– GeoEdge maintains and regularly reviews and updates its privacy-related and information security policies.

Personnel– GeoEdge requires new employees to sign non-disclosure agreements according to applicable law and industry customary practice.

Encryption– we encrypt the data in transit using secure HTTPS protocols.

Database Backup– databases are backed up on a periodic basis for certain data and which are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity and are tested regularly to ensure availability, and are accessed only by authorized personnel.

However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

HOW TO ACCESS AND LIMIT OUR USE OF CERTAIN INFORMATION

You have certain rights in relation to the Personal Data that we or our co-controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable co-controller directly. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

DATA RETENTION

Subject to applicable law and our (regulatory) obligations (including but not limited to any PCI requirements, we retain information as necessary for the purposes set forth above. Please note that our retention policy may vary between the different types of Services. In addition, retention by any of our processors may vary, in accordance with the processor’s retention policy. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice. We may also retain your information in an anonymized form. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether those purposes can be achieved through other means, as well as applicable legal requirements. Notwithstanding the above, we save electronic mail correspondents with you in case there will be future dispute and we also save any legal related documents, for future legal and audit use, all subject to applicable law.

Please contact us through the contact information listed below if you would like details regarding the retention periods for different types of your Personal Data.

WHAT ARE COOKIES?

A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.

We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.

HOW WE USE COOKIES

We use cookies and similar technologies for a number of reasons, for example, in order to help personalize your experience and to help personalize the ads we serve you.

The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories: