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.
- 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.
- 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
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.
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.
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.
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:
- We will transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
- Where we use providers based in the US, we may transfer data to them if they have been certified by the EU-US Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US or any other arrangement which has been approved by the European Commission.
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.
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:
- Right of Access and Data Portability. You have a right to know what Personal Data we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Data you provided to us (excluding information that we obtained from other sources) in a structured, commonly used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Data to another party. If you wish to exercise this right please contact us letting us know what information, in particular, you would like to receive and/or transmit. Subject to applicable law, we may charge you a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Data about another person. Where we are not able to provide you with the information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
- Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
- Deletion of Personal Data. In certain circumstances, you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please contact us, using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Data provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Data. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should also delete our App from your mobile devices and terminate your account and/or agreement with us and clear our cookies from any device where you have used our App. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
- Account Deactivation. You can ask us to deactivate your account by contacting us using the information below. In order to deactivate your account, we may ask you for additional information.
- Right to Object. Subject to applicable law, you may have the right to object to the processing of your Personal Data for certain purposes, including for the purpose of direct marketing.
- Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
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.
- A “session cookie” is temporary and will remain on your device until you leave the Site.
- A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
- First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
- Information may also be collected through web beacons, which are small graphic images (“pixel tags”), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.
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.
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:
Why We Use These Cookies
These cookies are necessary in order to allow the App and/or Site to work correctly. They enable you to access the App and/or Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
HOW TO ADJUST YOUR PREFERENCES
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.
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.
Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Data from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at [email protected]. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send, as well as through your account settings. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt-out of receiving them. Should you not wish to receive such communications you may cancel your account, subject to the terms of your agreement with GeoEdge.
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.
If you do not agree with the terms hereof, please do not use the App and/or Site and/or Services. We may update this Privacy Notice from time to time –in which case, we shall notify you of such changes. We will post the updated Privacy Notice on our website page. Please come back to the Site every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.
COMMENTS AND QUESTIONS
Last updated: August 2018