This Policy sets out, in particular: (i) what information we collect about the Users on the Website, (ii) how we collect that information, (iii) how we use that information, (iv) how we process that information, (v) to whom we disclose that information, (vi) how we protect that information and (vii) what are your rights and how can you exercise them.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
Personal Data may be freely provided by you, or, in case of usage data, is collected through the use of this Website. Collection of some Personal Data may be necessary for the availability or the correct functioning of the Services or Website. Not providing some other Personal Data requested by this Website is without consequences to the availability or the functioning of the Service, unless otherwise specified further in this Policy. The Website may also be used by a registered User or by a User without registration, please note that this does not affect collection of Personal Data via different means e.g. cookies.
Information you provide directly to us
We collect information about you when you register for an account, create and/or modify your profile, or when you allow connectivity with your social network accounts. This information includes first name, last name, email address, and/or username and/or username or user ID from your social network accounts, if you choose to use them as a log in method.
Information you provide to us when you use our Website or Services
We also collect information through your use of our Website or Services, including actions such as logging into your account and/or using your account. The content (i.e. any information or data that you create, upload, post, send or share via our Website) may be transmitted through and stored in our systems. This information include your browsing history on the Website, bookmarked quotes, made comments, the length of time spent on certain pages, the website Uniform Resource Locator (“URL”) from the website you were visiting before coming to this Website, which URL you visit next (i.e., if you followed a link to one of the providers or vendors we recommended), device type, what browser you are using, internet service provider, date/time of visit information, operating system, and other usage data. We also collect information on how you use our Website or Services through your computer, phone or another device that you use to access our Website or Services through Cookies and/or other similar technology.
HOW DO COOKIES WORK?
Cookies consist of portions of code stored on your device in order to help us collect information about your activities. Cookies enable us to store your preferences and settings, remember your log-in details, provide customised content and marketing communication, understand which part(s) of our Website and Services are the most popular and analyse Website operations.
You can configure your browser to accept all Cookies, refuse all Cookies, or indicate when a Cookie is being sent. It is worth noting that the Website is designed for you to work using Cookies and therefore some Website features or Services may not function properly without Cookies.
You can manage preferences for Cookies directly from within their own browser and prevent - for example - third parties from installing Cookies. Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website. Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.
Users may also follow instructions provided on the subsequently linked initiatives by the EDAA (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Company thus recommends that Users make use of these resources in addition to the information provided in this document.
HOW DO WE USE YOUR PERSONAL DATA?
We may use the information we collect about you for the following purposes:
In order to upload content to our Website, you must register on the Website and create an account.
For this purpose, the following applies:
- Personal Data processed: First name, last name, email address, and/or username or user ID from your social network accounts, if you choose to use them as a log in method.
- Retention time: We process your Personal Data only during the time you have an account on the Website.
When you use Services, regardless whether you have registered for an account or not, we process the information in order to ensure the functioning of the Services (for example by showing you relevant and personalized content). For this purpose, the following applies:
- Personal Data processed: Country of presence, device and online identifiers, other usage data.
- Retention time: We process your Personal Data for six months since your last visit on the Website.
We process your Personal Data in order to answer your questions and provide you with customer support. This processing occurs when you contact us via email, through the Website or otherwise regardless whether you have an account on the Website. For this purpose, the following applies:
- Personal Data processed: First name, last name, email address, and username.
- Legal Basis for processing: The processing is necessary for the purpose of our legitimate interest in maintaining customer satisfaction.
- Retention time: We process your Personal Data for two years after your request is closed.
We gather information about your use of the Website and the Services in order to analyse customer behaviour and to improve our Website and/or Services. For this purpose, the following applies:
- Personal Data processed: Device and online identifiers, other usage data.
- Legal Basis for processing: The processing is necessary for the purpose of our legitimate interest in improving the Services and functions of the Website (art. (6) (1) (f) of the GDPR).
- Retention time: We process your Personal Data for a maximum of two years after your last visit on the Website. After this period, we process the information only in an aggregated and anonymized form.
When you visit our Website, the advertisement you see may be customized based on your previous behaviour on Internet. We do not process your Personal Data ourselves, but we allow third parties to access your Personal Data through our Website. Please refer to privacy policies of respective third parties in this document.
HOW DO WE PROCESS YOUR PERSONAL DATA?
The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. No automated individual decision-making that would produce legal effects concerning you or similarly significantly affect you takes places during the processing of your Personal Data.
TO WHOM DO WE DISCLOSE YOUR INFORMATION?
In addition to our Company, the Personal Data may in some cases be accessible to certain types of persons in charge, involved in the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by our Company. If required by law, we have concluded Data Processing Agreements with these external third parties. These agreements bind the external third parties, among other things, to process the Personal Data only in accordance with our instructions and in compliance with data protection laws, and to take all necessary measures to protect the Personal Data. These entities are not allowed to use your information for purposes other than providing services for us.
Some Personal Data, as explained above, are collected by third parties for their own purposes. These third parties act as data controllers and their own privacy policies apply. The up-to-date list of these third parties and their applicable privacy policies is at the end of this Policy.
WHAT DO WE DO TO KEEP YOUR PERSONAL DATA SECURE?
In order to ensure the protection from unauthorised access to or unauthorised alteration, disclosure or destruction of information we collect and process, we have adopted among other things organisational and technical measures consisting of physical, electronic and managerial procedures to safeguard and secure the information we collect about you through this Website. Please note that the security of your Personal Data depends also on your own behaviour. The security of your Personal Data may be compromised as a result of transferring or handling your log-in information or other Personal Data by you in an unsecure way.
WHAT ARE YOUR RIGHTS under the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA)?
You may exercise certain rights regarding your Personal Data processed by us as the data controller:
- Access your Personal Data: You have the right to learn if your Personal Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Personal Data undergoing processing.
- Verify and seek rectification: You have the right to verify the accuracy of your Personal Data and ask for it to be updated or corrected.
- Have your Personal Data deleted or otherwise removed: You have the right, under certain circumstances, to obtain the erasure of your Personal Data from us. This right applies for example, when you withdraw your consent or when the Personal Data is no longer necessary in relation to the purposes, for which they were collected or otherwise processed.
- Restrict the processing of your Personal Data: You have the right, under certain circumstances, to restrict the processing of your Personal Data. This right applies for example, when you contest the accuracy of the Personal Data or when the processing is unlawful.
- Receive your Personal Data and have it transferred to another controller: You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Object to processing of your Personal Data: You have the right to object to the processing of your Personal Data if the processing is carried out on a legal basis other than consent. Where your Personal Data is processed for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to the particular situation to justify the objection. If we do not demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims, we will no longer process the Personal Data.
- Withdraw your consent at any time: You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- Lodge a complaint. You have the right to bring a claim before competent data protection authority.
HOW CAN YOU CONTACT US AND EXERCISE YOUR RIGHTS?
Our general contact information is INTERNET ADVERTISING LIMITED, company registered in Hong Kong, with its registered office at Room 2303, New Tech Plaza, 34 tai Yau Street, San Po Kong, Kowloon, Hong Kong, which is the data controller of any Personal Data, which is required to be processed in relation to your use of Website.
THIRD PARTY CONTROLLERS