PRIVACY POLICY
Last Revised: July 01, 2020
PubMax Ltd. (“PubMax”, “we”, “our”, or “Company”) is committed to comply with privacy rights.
PubMax is an online platform enabling our business partners – third party advertisers and publishers (collectively “Business Partners”) to display advertisements and marketing materials to end users (“User”) who use or otherwise interact with certain publisher’s mobile webpages and desktop websites (“Digital Assets” and collectively, the “Services”).
This privacy policy (“Privacy Policy”) provides transparent disclosure regarding our privacy practices related to the Personal Information (as defined below) collected from Users, visitors of our website available at www.pubmax.com (“Website” and “Visitor”, respectively) and our Business Partners (User, Visitor and Business Partner shall be collectively referred to herein as “you”).
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Service which this Privacy Policy is incorporated thereto by reference (collectively, the “Terms”).
We have included below information about which data is collected, how we process and use your data, but before we would like to explain the basis on which we do so:
1. Where you are our Business Partner, we process your Personal Information in order to perform our contract with you;
2. If we have a legitimate interest in processing Personal Information, such as for direct marketing, or security purposes when you access our Website or use our Services; or
3. We will also process your Personal Information where you have provided us with consent to do so, in the event required under applicable law.
INFORMATION WE MAY COLLECT
We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non–Personal Information”). We are not aware of the identity of the individual from which we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while Users are using the Services or a Visitor is accessing the Website. Non-Personal Information which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, Visitors’ action in the Website, or approximate geo-location.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”).
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
You are not required by law to provide us with any information. You can always avoid from providing us certain Personal Information; however, you acknowledge that it may prevent you from engaging in certain Services or using certain features of the Website.
We are considered as the Data Controller of the Personal Information we collect from our Website’s Visitors and Business Partners.
Information we collect from Visitors of our Website
| Type of Personal Information | Purpose of Processing |
|---|---|
| Contact Details
In the event you contact us for support or other inquiries, either through the online form available on the Website, by sending us an email or by other means of communications we make available, you will be requested to provide us your name, email address, and may provide us with your phone number. |
We will use this information solely for the purpose of contacting you, responding to your inquiries and provide you with the support or information you have requested. |
| Online Identifiers & Technical Usage Information
When you access our Website, we may, either directly or indirectly collect your IP address. We may also collect technical Non-Personal Information, as detailed above. |
We process this data under our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Website, and the way in which we offer it; (ii) enhancing your experience with the Website; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow.
Note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address. The IP may be collected by our third-party analytic partners that offer ways to opt-out, all as detailed below. |
| Recruitment
In the event you are interested in joining our team, and wish to submit your CV, you will be required to provide us your name, email address, and CV. |
Your provision of Personal Information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management. |
Information we collect from our Business Partners
| Type of Personal Information | Purpose of Processing |
|---|---|
| If you are our Business Partner, we may collect Personal Information that you are required to submit to us when you engage with us, such as your or your personnel’s (in the event applicable) name, email address, other contact details, and payment details (applicable solely in the case of sole trader). | This information will be processed for the purpose of performing our contract with you as well fulfilling our legitimate interests.
We use this information to provide you with the Services you have requested. We will use your email address in order to send you needed information related to the Services and our business engagement. In addition, we may send you marketing and promotional messages, offers and discounts. You are able to opt out unsubscribe through a designated link in the email that we will send or contacting us at: [email protected] Please note that if you choose to unsubscribe from direct marketing, we may still hold your contact details and contact you for updates regarding your use if the Services or any other relevant Service-related information. |
Users of PubMax Service
In the event you are a User interacting with the Services, we will not collect or store any information about you, however, our Business Partners using our Services, may collect certain information for the purpose or displaying personalized ads. This Personal Information may include online identifiers and other behavioral related information, including IP address and mobile related identifiers (for example Advertising ID and IDFA). Please refer to the privacy policy of the Digital Asset you are interacting with for more information. Please note that this Privacy Policy refers solely to our privacy practices. We do not controller nor monitor nor have any responsibility to our Business Partners’ privacy practices. Notwithstanding the above, for certain information regarding opt out alternatives (whether you are using desktop or mobile device), please see the Cookies and Tracking Technologies paragraph below.
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the Website and Services, we may collect information as follows:
· Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies to gather some information automatically.
· Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a physical agreement, contact us communications, etc. all as detailed in this Privacy Policy.
SHARING INFORMATION WITH THIRD PARTIES
PubMax will not share any Personal Information it collects with any third party. Other than under the following circumstances: (i) Compelled Disclosures. To satisfy any applicable law, regulation, legal process, subpoena or governmental request; (ii) Enforcement of our Rights. To enforce this Privacy Policy and/or the Terms of Service, including investigation of potential violations thereof; (iii) Fraud Detection. To detect, prevent, or otherwise address fraud, security or technical issues; (iv) Business Transfers. When PubMax is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (v) Service Providers. To collect, hold and/or manage your Personal Information through PubMax’s authorized third party service providers, as reasonable for business purposes; (vi) Explicit Consent. Pursuant to your explicit approval prior to the disclosure.
For avoidance of doubt, PubMax may transfer and disclose or otherwise use Non-Personal Information or information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable way, at its own discretion.
DATA RETENTION
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
USER RIGHTS
Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Information. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party.
The principal rights under applicable data protection law in relation to Personal Information are as follows: the right to access any information which is provided to us; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority; and the right to withdraw consent (to the extent applicable).
We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information, depending on your relationship with us.
If you wish to exercise any or all of the above rights, please contact our Data Protection Officer at: [email protected] and let us know that you wish to exercise your right of access and specify the Personal Information you refer to.
Note that, in the event you are our Business Partner, you may update certain information through you online account, if applicable.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
COOKIES POLICY AND TRACKING TECHNOLOGIES
When you access or use our Website, PubMax may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your service experience much more convenient and effortless.
We currently use Google Analytics services which involves the use of cookies. These cookies are placed in order to track and analyze the use of our Website, for internal purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend you review Google’s policies located at: google.com/policies/privacy/partners. Google Analytics’ currently available opt-outs for the web tool are available at: https://tools.google.com/dlpage/gaoptout.
If you are a User interacting with our Service through mobile application, note that we are using an SDK component known as Google Apps Manager. For additional information of our use of Google products, click here.
It is easy to block the Local Storage. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited.
In this regard, following are some links which you may find useful. Note that, in the event you are a User interacting with our Services, you may opt out from our Business Partners data collection using the alternatives detailed below.
Browser Opt-out:
· Firefox
· Safari
· Edge
· Opera
Mobile Opt-out:
· Learn how to opt-out from Android
· Learn how to opt-out from iOS
· You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
Self-Regulation Opt-out:
You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services such as (1) the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or (2) the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page or (3) If you wish to opt out of interest-based advertising, you may click here.
Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.
SECURITY
We take great care in implementing and maintaining the security of our Website, PubMax Services and your information. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any such. We have implemented technical, physical and administrative security measures to protect the Personal Information, including without limitation by using industry standard encryption (SSL). In addition, we limit access to your information on our servers. The data collected by us is stored in the AWS data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Website and Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
PROTECTING CHILDREN
The Website is intended for individuals over the age of sixteen (16). Therefore, PubMax does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Website.
CHANGES TO THE PRIVACY POLICY
The terms of this Privacy Policy will govern the use of the Website, PubMax Services and any information collected therein. PubMax reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the Site. Such substantial changes will take effect seven (7) days after such notice was provided on the PubMax Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the PubMax Services after the Last Updated date will constitute acceptance of, and agreement to be bound by, those changes.
DATA TRANSFER
We may store or process your Personal Information in the EU, United States or in other countries. Thus, any information you provide to us through your use of our Websites or Service may be transferred to and processed in countries other than the country from which you accessed our Websites or Service. We will take appropriate measures to ensure that your Personal Information receives an adequate level of data protection upon its transfer.
DO NOT TRACK DISCLOSURE
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.
ADDITIONAL INFORMATION AND CONTACT US
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: [email protected] or and we will make an effort to reply within a reasonable timeframe.
By contacting PubMax you warrant and agree that you are free to do so, and that you do not provide PubMax with information, which violate any third-party intellectual rights (“Information”). Without degrading from the aforesaid, all rights, including intellectual property, arising from the communication will be owned by PubMax and will be considered as PubMax’s confidential material. It is clarified that any use of the Information, will be done in PubMax’s sole discretion, and PubMax is not obligated to use all or part of this Information.
DATA PROTECTION OFFICER
If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: [email protected]. Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.