new version updated 3rd of May 2018
We are the sole owners of the information collected on this Site, through the Platform, Software or Services. We only have access to/collect information that you voluntarily give us. Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services.
“Cookies” - small files that the Site, web-based software services or service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the Website's or service provider's systems to recognize your browser and capture and remember certain information.
“Personal Data” - data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual.
“Non-Personal Data” – data in a form that does not, on its own, permit direct association with any specific individual.
“Services” – access to some functionality that the user receives when registering on the Platform (for example, billing and SDK, which can be integrated into the mobile application, etc.), or using other products of ORANGEAR.
“Platform” - a software solution owned by us used for managing and serving campaigns, tracking, aggregating statistics, and interacting with clients and affiliates.
“Software” – refer to Platform with all of its functions, other products of ORANGEAR (e.g. VPN, Offer Checker etc.) and the Services (as determined above).
“Pseudonymisation” – replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified.
“Anonymisation” – processing data with the aim of irreversibly preventing the identification of the individual to whom it relates.
“Regulation” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
“Law” – data protection and other laws and regulations of state of California, USA applicable to the subject matter, and Regulation as determined above.
- Contact Information: When you access or otherwise use the Site or register / sign up for the Software, we may collect certain contact information from you, such as your first and last name, company name, city, state and zip code, email address, office and mailing address, phone number, password, skype name, counter-party's names, company website or other contact details to help you with your experience (collectively, "Contact Information"). When using Software and accompanying services, you will be required to provide additional information that may include a credit card number, account number, beneficiary’s name and details, account holder, bank name, pay pal information, pay pal account details or other banking and payment information ("Billing Information"), as well as information necessary to secure your transactions, including the whitelist of IP addresses. This information is required by us to verify your identity, to establish your company’s account, and set up your Services.
You may set your browser to notify you or decline the receipt of Cookies; however, certain features of our Site and Software may not function properly or be available if your browser is configured to disable Cookies and/or other technical means that allow to receive data pointed above.
- Service Information: In order to provide Services to you and to improve your experience, we may collect information that is created or provided by you in connection with your use of the Services (collectively, “Service Information”), including ticket logs and information about your actions in various client areas on the Site or within the Software. Service Information may include Personal Data. We use Service Information to market our Services to you in a more personalized manner.
- Billing information: in order to execute transactions upon providing Services, we can request an information related to your banking or other accounts. The user signing in the Software warrants that he is a legal representative of the business entity and is entitled to provide this kind of information regarding such entity.
In addition to the uses described above, we may use information collected from you when you use Software, register or sign up for the Software, sign up for our newsletter, respond to a survey or to our marketing communication, browse our Software, or use Site or its features in the following ways:
- We will store and use Service Information for the purpose of conducting business with you. Use of the Service Information is also governed by the agreements you enter into with us in connection with the Services (Terms and Conditions, Agreements, Insertion orders, etc.). Please refer to the specific Terms and Conditions, Agreements, Data Processing contracts etc. for provisions concerning confidentiality and data protection regarding specific relations appeared out of such agreements (if any). In the event of any conflict between this Policy and the specific Terms and Conditions, Agreements, Data Processing contracts etc., the latest will prevail.
- We may use any information collected from you (Personal and Non-Personal Data): (i) to personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested; (ii) to improve our Software in order to better serve you and/or to provide Services more effectively; (iii) to ensure continuous improvement and development of the Software; (iv) to administer the Site, the Software and accompanying Services and to diagnose possible problems; (v) to send periodic emails regarding your order or our other products and services.
- We may collect and store details of how you use our Software, including search queries. This information may be used to improve the relevancy of results provided by our Software. Except in limited instances to ensure a quality of our Software over the Internet, such information will not be associated with your IP address.
- If we do combine Non-Personal Data with Personal Data the combined information will be treated as Personal Data for as long as it remains combined.
- As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit Software, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.
- In some of our email messages, we use a “click-through URL” linked to content on our Site or Software. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our Site or Software. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
- Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
- To provide location-based services we may collect, use, and share precise location data, including the real-time geographic location of your access to Site and/or Software. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used to provide and improve location-based products and services. We may be obliged to process such information in order to comply with law or Regulation.
- We can collect Personal Data for protection of our users from fraud or other illegal activity which can be fulfilled with unlawful use of your Personal Data on Site and/or Software (as a way of example, we may collect Personal Data to form conversion IP whitelist).
- We can provide some of your Personal Data to our partners, contractors, affiliates if it is necessary for performing agreements between you and us (e.g. Agreements, Insertion Orders etc.) or if it is an essential part of how our Software work.
- We can delete personal and Non-Personal Data any time we consider it appropriate and in compliance with the purposes we collected it for, unless we are required by law or Regulation to store such information for particular period of time.
We may use third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) to perform certain business-related functions. Examples of such functions include, but are not limited to: data storage services, database maintenance services, and payment processing. When we use such third party to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will make sure that each third party will be required by contract to keep such Personal Data confidential, make necessary steps to protect such Personal Data and not to use it for any purpose other than providing services to us and other provisions as required by law and Regulation.
Before transferring any Personal Data to third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) we shall make reasonable check of such third party regarding its compliance with law and Regulation. We will make commercially reasonable efforts to store Personal Data of individuals in the regions where they live or operate in cases if we are required by law or Regulation to do so (e.g. Personal Data of EU citizens in EU or countries acknowledged by relevant authority as having appropriate level of data protection). If storing of Personal Data in such way is not commercially reasonable, we will ensure that third party processors are bound by agreement which contains obligations of the processor to provide at least minimum necessary level of security and other provisions as required by law or Regulation (e.g. as required by approved model data processing agreements adopted by relevant data protection authority). As well, we will ensure that such agreement contains obligation of processor to adopt necessary provisions into his agreements with sub-processors (if any). Herein you give us your free unambiguous consent to store your Personal Data (and Non-Personal Data, if applicable) outside of your country of residence (registration, domicile, center of vital interests, economic region, etc.).
We may disclose Personal Data if required to do so by law (Regulation) or to comply with a legal obligation, or if we believe in good faith that such action is necessary to: (i) protect our rights or property and our customers or (ii) protect the property or safety of users of the Site or the Software and the accompanying services, legal owners of the Site or the Software; or any third party. If we will be required by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, court or administrative order.
Please note that your non-personally identifiable information (Non-Personal Data) may be provided to other parties for marketing, advertising, statistics or other uses. This is not linked to any Personal Data that can identify any individual person.
By refusal to provide data necessary for registration, you refuse to receive our Software and Services.
In case you act as an agent for a third party during registration or use of our Site/Software you should be duly authorized to provide us with necessary amount of the data of such third party. By registering, you represent and warrant that you are duly authorized.
However, no method of transmission or method of electronic storage is 100% secure. We do not guarantee that our Site or the data stored during your use of the Software is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Site, the Software or the Services are or will be protected from all viruses, security threats or other vulnerabilities or that your Personal Data and Non-Personal Data will always be secure.
To make sure your Personal Data is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the company. Only employees who need your Personal Data to perform a specific job (e.g. billing or customer service) are granted access to relevant personally identifiable information (Personal Data). All of our employees sign relevant NDA and our security system is designed to ensure possibility of identification of all the employees who had access / accessed Personal Data of our users.
Your obligations regarding security of your data are the following: not to disclose your contact information and other data which allows/enables unauthorized access to the Software and/or Site or any other actions connected to the Software and/or Site on your behalf; make reasonable efforts to secure your actions in Internet and your use of the Software. You are solely responsible for the correctness, appropriateness fullness etc. of the provided data and warrant to us that you have all rights to provide us with such data.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage our users to be aware when they leave our Site/Software and to read the privacy statements of any other site that collects personally identifiable information (Personal Data).
When you use Site, Software, or applications or post on Site or Platform forum, chat room, board, or social networking service, the Personal Data and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Data you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. By submitting actions pointed above you grand us, our partners and affiliates a non-exclusive, unlimited, worldwide, royalty-free license to use, display, perform, copy, transmit, distribute, promote, alter, modify, manipulate or create derivative works with materials, texts, words, impressions and other information provided by you in such a way.
From time-to-time, our site requests information via surveys or contests. Participation in these surveys or contests is voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and address), demographic information (such as zip code, age level) and business information (types and amounts of Services used, targeting specifications). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site, and to notify the winners and award prizes (if any).
We understand the importance of taking extra precautions to protect the privacy and safety of children accessing Site and/or Software. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to use Site and/or Software, unless their parent provided verifiable consent or as part of the child account creation process (if this type of account is applicable). If we learn that we have collected the Personal Data of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, unless we are obliged to keep such data in order to comply with law or Regulation.
You acknowledge and voluntarily agree that we have no obligation of sending you via email or otherwise any notification regarding such change, though we have right to do so if consider it appropriate.
We store your Personal Data for 3 month and make a revision of it after that period. During such revision, we may either delete all of your Personal Data or keep it collected for the next 3 month if: we are providing you Services; you use Software and Site; we are in the middle of dispute or you are our debtor; such information is still necessary for the purposes we collected it. We can delete your Personal Data any time and not wait for 3 month period to end if purpose we collected it for no longer apply. We make no warranties your Personal Data will be available for any specific period of time (3 month, or less or more etc.). Please consider, that we have no obligations to notify you when deleting your Personal Data and can do it at our sole discretion.
In cases of breach of security which lead to unauthorized access to your Personal Data, we: will let you know about this incident without undue delay as soon as we become aware of such breach and make all reasonable efforts to minimize the harm and restore necessary safety measures. We can notify (inform) you about breach of your Personal Data at our sole discretion in the following ways we consider most appropriate: via your contact email, by phone, in your personal account, in national news, on our Site or any other way which allows you to make necessary steps to minimize the possible harm without undue delay. Such notification will include general information about the breach, possible risks and our steps to minimize them – to the extent possible in relevant circumstances. You are solely responsible to notify your third parties if their Personal Data is part of such breach (if your are the one who provided such information to us). Our notifications shall not constitute our acknowledgment of any kind of fault (guilt, liability) for the breach.
Do Not Track Signals
We do not track you by ourselves over time and across third-party websites to provide targeted advertising and therefore respond to Do Not Track (DNT) signals in a way that we use the usual types of tracking systems that are a standard practice in advertising, e.g. Google AdWords. As well, be aware that some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Notice for Minors
If you have any questions, concerns or complaints regarding the way we collect and handle your Personal Data, or regarding contact person (representative) for compliance with law and Regulation please contact us by firstname.lastname@example.org