Date of last revision: 10 June 2020
At Affise, we are committed to respect the privacy choices of our clients and Website visitors.
You will also find below the important information about your rights in relation to your personal data, so please read the policy carefully.
Affise Technologies Ltd or Affise Inc. (“Affise”, “us”, or “we”) acts as a controller of your personal data. Affise Technologies Ltd is incorporated and existent in the Republic of Cyprus with address 38 Spyrou Kyprianou, Mayfair Business Centre 2nd floor, office no. 6, 4154, Kato Polemidia, Limassol, Cyprus. Affise Inc. is a corporation registered in the State of Delaware, 160 Greentree Drive, Suite 101, Dover, County of Kent, 19904. Contact email for bot entities: firstname.lastname@example.org.
By accessing the Website or using our Services, you become subject to this Policy. Your acceptance of the terms of this Policy, in their entirety, shall be effective to your employees, if any.
Affise offers performance marketing software as a service solution through the Website. It allows to upload and download the data to and from the Software, to customize the built-in features and tools of the Software in order to retrieve, gather, process and analyze the clients’/customers’ data as well as to review and analyze data processing results via the Software or by downloading the reports and data. In the framework of these activities the processing of the personal data occurs upon the customers’ instructions. The data processed on the clients’/customers’ behalf relates to their partners with which the clients/customers conduct business and end-users who use or interact with the clients’/customers’ websites, products, services, advertisements and/or mobile application services. In relation to processing of such personal data, Affise is a data processor. This processing within the free trial of the Software and the subsequent use of the Software, if the client/customer chooses to continue access and use of the Software, is governed by the data processing agreement executed between Affise and the client/customer.
- What information we collect and how we use it
“Personal Data” is any information relating to identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly.
We collect the following Personal Data about you:
1.1. Information we use to provide services
Contact Information. When you register / sign up for the Services, we may collect certain contact information from you, such as your first and last name, organization name, city, state and zip code, email address, and phone number or other similar contact details to process your registration request, to contact you regarding it and help you with your experience.
Billing Information. When purchasing Services, you will be required to provide additional information that may include a credit card number or other banking or payment information. This information is required by us to verify your identity, to establish your company’s account, to set up your Services and to enable payments for the Services to be made or to invoice you for them.
Service Information. In order to provide our Services to you, to improve them and to enhance your experience, we may collect information that is created or provided by you in connection with your use of the Services, including order information, chat logs, email logs and information about your actions in various client areas on the Website.
Third Party Information. We may obtain information about you from third party or public sources and add it to your account Contact Information. This combined information may be used by us to enhance our ability to provide Services to you, to ensure that we are paid for Services.
We will use your Contact Information and Billing Information to provide Services and to provide you with access to the Services you have ordered, as well as support services, technical updates or updates on changes in our usage policies. The legal basis for us to use your Contact Information, Billing Information and Service Information is the agreements you enter into with us in connection with the Services (the “Services Terms”) and performance of these agreements as well as taking steps at your request prior to entering into them.
We may also use any information collected from you: (i) to personalize user’s experience; (ii) to improve our Services in order to better serve you and/or to provide Services more effectively; (iii) to allow us to better service you in responding to your customer service requests, (iv) to ensure continuous improvement and development of the Services; (v) to administer the Website and to diagnose possible problems; (vi) to administer a contest, promotion, survey or other Website feature; (vii) to send periodic emails regarding your order, your use of Services or similar Services you might be interested in.
1.2. Use of information for direct marketing
We may use your Personal Data (full name, contact email address and country) to send you company updates and marketing offers about Services you use (used) or similar services which we provide (provided) to you. You may object to such processing and may refuse from receiving such communications (1) by contacting us pursuant to Section 8 when we first collect your details or (2) by pressing unsubscribe at the end of the message or sending an email to us (see Section 8). In case you use the first option to opt out, we will respond to your request within a reasonable time period. If you opt out, we will still send you non-marketing communication regarding your account or our ongoing business relations (if you are our customer/client).
We may use your Personal Data (full name, contact email address and country) to carry out marketing of Affise products and Services, in which you have actively indicated an interest through our Website contact/request form, by way of periodic direct marketing communication email messages, provided that our legitimate interests in carrying out these marketing activities are not outweighed by any prejudice or harm to your rights and freedoms. You may object to such processing and may refuse from receiving such communications (1) by contacting us pursuant to Section 8 when we first collect your details or (2) by pressing unsubscribe at the end of the message or sending an email to us (see Section 8). In case you use the first option to opt out, we will respond to your request within a reasonable time period.
We use Service Information to market our Services to you in a more personalized manner and to allow us to deliver the type of content and product offerings in which you are most interested, to advertise or market our business, and to tailor offers, promotions, etc.
Legal basis for processing described in sub-section 1.2 is our legitimate interests to increase our sales and grow our business.
1.3. Browsing Information and Cookies
“Cookies” are small files that the Website or its service provider transfers (if you allow) to your computer’s hard drive through your Web browser that enables the Website’s or service provider’s systems to recognize your browser and capture and remember certain information.
We use Local Storage (HTML5), and our third party utility partner uses Local Shared Objects (Flash cookies) and Local Storage (HTML5) to store content information and preferences, and to display advertising based on your web browsing activity. Various browsers may offer their own management tools for removing HTML5. If you want to manage Flash cookies, please visit at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html .
You may set your browser to notify you or decline the receipt of Cookies; however, certain features of our Website or Services may not function properly or be available if your browser is configured to disable Cookies. Such cookies are essential for our Website to function properly. Other cookies are not particularly necessary for the Website to function and are used specifically to collect your personal data via analytics.
1.4. Third Party Tracking Technologies on our Website
You can learn more about how to control your data and exercise your rights in our third party partners’ relevant privacy documentation (links and relevant information can be found below).
When you access a Baidu products by or through a mobile device, Baidu may receive or collect and store a unique identification numbers associated with your device or the Baidu products (including, for example, a unique device ID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), MAC address, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and longitude) or similar information regarding the location of your mobile device.
Baidu may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) provide and monitor the effectiveness of Baidu products; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and Baidu products; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance Baidu products.
Bing is a web search engine owned and operated by Microsoft which we use in advertising purposes to drive traffic to our website, raise brand awareness, and increase our online sales as a part of our marketing plan. Microsoft collects data to operate effectively and provide you with the best experiences while using their products. You provide some of this data directly, such as when you create a Microsoft account, administer your organization’s licensing account, submit a search query to Bing, register for a Microsoft event, speak a voice command to Cortana, upload a document to OneDrive, purchase an MSDN subscription, sign up for Office 365, or contact them for support. They get some of it by recording how you interact with their products by using technologies like cookies, and receiving error reports or usage data from software running on your device. The data collected can be stored in Bing products and used by us in order to optimize advertising campaigns and increase their effectiveness. Find out more here https://privacy.microsoft.com/en-us/privacystatement
Facebook Social Plugins
This website uses social plugins (“plugins”) from the social network facebook.com which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins are identified by one of the Facebook logos or the amendment “Facebook social plugin”. The list and the look of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
If you are a Facebook member and do not want Facebook to collect data on you via our website and to combine such data with your Facebook membership data, you need to log off from Facebook before accessing our website. Furthermore, you may also block social plugins by downloading and installing add-ons for your browser.
This website uses social plugins that are provided by Twitter Inc.,1355 Market St, Suite 900, San Francisco, CA 94103, USA, and can be identified by the Twitter logo or e.g. the words “Tweet” or “Twitter”. The plugins enable the user, inter alia, to share an article or a page of this website on Twitter. If you access a website that includes this plugin, your browser sets up a direct connection to Twitter’s servers. Twitter transfers the plugin’s content directly to your browser which will then integrate it into the website. Therefore, we have no influence on the extent or content of the data that Twitter collects via its plugin, and thus, can only inform you based on our state of knowledge.
1.5. Rights of end-users with whom Affise does not have a direct relationship
When Affise operates as a data processor on the data controllers’ (clients’/customers’) instructions, it is not an end-user facing company. Direct relationship is formed between end-users and our clients/customers. For this reason, such end-users must reach out to the data controllers in order to exercise their end-user (data subject) rights. In the majority of cases, the data controllers are advertisers of products advertised to the end-users via mobile applications, mobile or desktop web. In some cases, it can also be publishers, agencies or ad networks. In case the end-user wishes to delete, access, correct or export its personal data, he/she needs to contact the data controllers providing explicit information in his/her request.
If the data controllers receive requests from end-users wishing to exercise their rights (e.g. erasure) with regard to the personal data the data controllers share with Affise, the data controllers must communicate that obligation to Affise with all information necessary to fulfil such requests.
2. To whom we disclose your personal data
We may disclose your Personal Data to (1) our employees who are in contact with you or who are responsible for marketing, customer success, customer support and/or employees from IT departments, (2) our affiliated companies, (3) third-party suppliers/vendors.
2.1. We use third party suppliers/vendors to perform the following business-related functions: data storage services, data analysis, Website hosting, database maintenance services and payment processing. External legal consultants/advisors or debt collection agencies can be used by us in order to protect our or third parties’ interests and/or recover a debt caused by your failure to pay for our Services. These suppliers and vendors may receive or have access to your personal data. When we employ such third party suppliers/vendors 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 put our reasonable efforts that each third party supplier/vendor will be required by a contract to keep such Personal Data confidential and secured and not to use it for any purpose other than providing services to us.
Personal data processed through our Software on the data controllers’ behalf/instructions is disclosed only to our affiliated company located within the EU and other subprocessors providing cloud providing services to us. More detailed information can be found in data processing agreements which govern processing of the personal data by Affise on the data controllers’ behalf.
2.2. We may share Personal Data with the owner of intellectual property rights to the Website and software used on it to the extent needed to perform certain business-related functions (e.g. updates, maintenance, support, etc.) for the purpose of providing Services to you.
2.4. We may disclose Personal Data to public authorities if required to do so by law or to comply with a legal obligation. If we are requested 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.
2.5. We reserve the right to sell, assign or transfer our business or assets. In any such event or similar event, including but not limiting to corporate sale, merger, reorganization, dissolution, etc., Personal Data may be part of the transferred assets. You acknowledge that such transfers may occur, and that any acquirer or successor of Affise may continue to use your Personal Data as set forth in this Policy.
2.6. Our employees have access to your Personal Data only to the extent their functions are required to provide our services or otherwise act on our behalf as set forth in this Policy.
2.7. Statistical/analytical data about our Website’s visitors/users may be accessed by (1) our employees in marketing, customer support, customer success and/or IT departments who are responsible for analyzing such data and for improving our Website and Services, (2) Affiliates, (3) third-party service suppliers/vendors.
3. Data storage period
Personal Data will be stored for as long as the Personal Data is required to provide Services or requested Website functionality.
In some cases, Personal Data may be stored for a period longer than indicated or despite withdrawal of consent or request to erase Personal Data, if storage of Personal Data is required in order to comply with our legal obligations, protect our or third parties’ legitimate interests/resolve disputes, maintain accurate financial and other records and/or in order to enforce our agreements.
When we use your Personal Data for statistical purposes (country), we will retain your data within 18 months.
When we use your Personal Data for direct marketing purposes (full name, contact email address and country), we will retain your data within 2 years from the moment when we received your data through the contact form on the Website (for those who are interested in use of our Software) or from the end of the free trial period (if you do not wish to continue access and use of the Software) or from the termination of the end-user agreement (as well as during the free trial period and the term of the agreement). This is the term during which we consider your data effective for us in terms of direct marketing unless you opt-out from receiving the marketing materials or exercise other data subject’s rights earlier; provided that we will need to retain certain information to maintain a record of your request.
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we have implemented appropriate technical and organizational security measures designed to protect data in our possession from accidental loss, misuse, alteration, disclosure, destruction and unauthorized access. In addition, we limit access to your Personal Data to only authorized staff and to those who have business need to know (and they will only process your Personal Data on our instructions and subject to a duty of confidentiality). We have put in place procedures to deal with any suspected or actual data security breach and will notify you and to the supervisory authority of a suspected breach where we are legally required to do so.
5. Links to Other Sites
For the convenience of our visitors, users and clients, the Website may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.
6. Social Media & Widgets
We will never knowingly collect any Personal Data and personal information about individuals under eighteen (18) years of age. If Affise obtains actual knowledge that it has collected personal information about an individual under eighteen (18) years of age, that information will be immediately deleted from our platform.
8. Your Rights, Questions and Complaints
8.1. You have a right to request rectification of Personal Data in our database (including Contact and Billing Information that you have provided to us) by contacting us at email@example.com. If you delete Personal Data or it is erased under your request (pursuant to your right to request erasure of your Personal Data), we will only retain such copies of the information as are necessary for us to protect our or third parties’ legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with us.
8.2. In certain cases, you may have a right to restrict processing of your Personal Data (so we only process your Personal Data in limited circumstances, including with your consent) or to object to processing of your Personal Data (so we no longer process your Personal Data). These rights can be exercised by contacting us at firstname.lastname@example.org.
8.3. In cases where processing of Personal Data is based on your consent, you have the right to refuse and revoke consent to the processing of your Personal Data by contacting us at email@example.com. Upon termination of processing of your Personal Data it can be difficult or impossible to provide Services to you.
8.4. You can request information about all Personal Data we have stored about you by contacting us at firstname.lastname@example.org. By contacting us at the aforementioned address, you may also exercise your right to data portability. The right to data portability entitles you to receive a copy of your Personal Data which you have provided to us in structured, common and machine-readable format insofar as it has not already been deleted.
8.5. You can use the right to lodge a complaint with your supervisory authority if, despite our commitment and efforts to protect your Personal Data, you believe your data protection rights have been infringed. The complaint can be lodged in the Member State where you live, work or where you assume the alleged violation took place.
8.6. If you have any questions, concerns or complaints regarding the way we collect and handle your information, please contact us by email at email@example.com (or firstname.lastname@example.org) or Affise Technologies, 38 Spyrou Kyprianou, Mayfair Business Centre 2nd floor, office no. 6, 4154, Kato Polemidia, Limassol, Cyprus.
8.7. Our data protection officer can be contacted by email at email@example.com.