Effective from May 23 2018
Except as explicitly set forth herein, OsAdsPro SRL (“Groovinads”, “We”, “Us” OR “Our”) does not collect your Personal Information through our Services. In limited instances, our Customers (as defined herein) provide us with their name, email address and business data, but we make no use of such data other than to do business with our customers. Furthermore, none of the Service Data we do collect, individually or grouped together, can be traced back to you.
Information Collection and Use
“Services Data” is data collected by us in order to allow us to provide the Services to you and to our customers that have entered into an agreement with us to provide Services (“Customers”). The Services Data is collected from your browser or directly from our Customers and includes information such as your IP address (which in certain instances may be truncated or rendered pseudonymous), a unique Customer ID number, the date and time of use of our Services, and your activity on Customers’ websites. We use Services Data to provide you Customer product and service recommendations and advertisements either on Customer websites or through Customer emails. In the future, we may decide to use Services Data to provide you such recommendations and advertisements through other forms of digital distribution.
EXCEPT FOR THE DATA OF OUR DIRECT CUSTOMERS, WE DO NOT COLLECT PERSONAL INFORMATION THROUGH OUR SERVICES
Cookies and Tracking Technology
We gather certain information automatically from our customers’ websites and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Services. We do not link this automatically collected data to other information we collect about you.
Disclosure of Aggregated Information
We may disclose aggregated information about the use of Services to business partners, prospective investors, and others. Additionally, we may produce industry-standard traffic reports for assessing use of Services. This information cannot be traced back to you personally.
Information Gathered by Our Customers or Other Third Parties
Except for limited instances described above where Customers provide email addresses to us, Groovinads does not come in contact with, and specifically disclaims any association with, any Personal Information collected by Customers from their consumer end users. Customers may include usernames in the user identification tags that they pass to us, but we have no control over such tags and use this information only as a database identifier. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to our Customer (the data controller). If requested to remove Personal Information from our servers we will respond within a reasonable timeframe.
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of information we process. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
We retain Services Data only for so long as it remains relevant to providing you with product recommendations and advertisements on our Customers’ Websites or to the extent permitted by law.
Our collection of Personal Information is limited to the receipt of email addresses from our Customers. We will retain this Personal Information for as long as needed to provide services to our Customers. If you wish that we no longer use your Personal Information to provide you services contact us at firstname.lastname@example.org. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Changes to Groovinads’s Corporate Structure
If Groovinads is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via e-mail and a prominent notice on our Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Changes and Updates
We may change or update this policy. When we do, we will also revise the Effective Date at the end of this policy. If we make any material changes to this policy, we will notify you by means of a notice on our Website prior to the change becoming effective. We encourage you to review this policy periodically to stay informed about our collection, use and disclosure of personal information.
International Visitors and Customers
EU data subjects
For persons located in the European Economic Area (“EU Data Subjects”), commencing on May 25th, 2018, we will process your personal information in accordance with the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (GDPR).
You should read the relevant laws and guidance from the regulatory authorities for a full explanation of your rights under the GDPR, but the following briefly summarizes some of these rights and how we handle them:
- You have the right to confirmation as to whether or not we process your personal information and, where we do, access to the personal information, together with certain additional information.
- You have the right to rectification of any inaccurate personal information about you and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- In some circumstances you have the right to the erasure of your personal information without undue delay.
- In some circumstances you have the right to restrict the processing of your personal information. For example, you have the right to object to our processing of your personal information for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal information for this purpose.
- You have the right to object to our processing of your personal information for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- In certain circumstances, you have the right to receive your personal information from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- If you believe our processing of your personal information violates data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged violation.
- In certain circumstances, you have the right to to invoke binding arbitration.
- Groovinads does not disclose personal data to third parties. Under certain circumstances, Groovinads may be compelled to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- You may exercise any of your rights in this section in relation to your personal data by written notice to us at the address listed below.
For EU Data subjects, we rely on the following legal bases to process your personal information:
- Performance of a contract: The use of your personal information may be necessary to perform the contract that you have with us or provide the service you ordered from us. For example, if you register to use our free trial and demo, we collect your information to administer your account and access to that free trial and demo.
- Legitimate interests: We may use your information for our legitimate interests, such as to provide you with the best suitable content of the Sites, emails and newsletters, to improve and promote our products and services and the content on our Sites, and for administrative, fraud detection and legal purposes.
We will only retain personal information from EU Data Subjects as long as necessary to fulfill the purposes for which the personal information was collected.
Our Website and Other Sources of Personal Information
Our Website requires a minimal amount of Personal Information to maintain account information and communicate with Customers and potential Customers regarding use of Services. Additional information may be needed in the future by us or by partners in order to provide Customers with additional products and services. We limit access to specific contact information internally to only those employees and contractors who design and maintain the system information stores or who have a reasonable need to come in contact with and make use of such information for account purposes.
Third Parties/Advertisers and Your Information
Links To 3rd Party Sites
If you post comments to the Blog pages on this Website, you should be aware that any Personal Information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in your comments. To request removal of your Personal Information from our blog, contact us at email@example.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. Alternatively, if you used a third party application to post such information, you can remove it, by either logging into the said application and removing the information or by contacting the appropriate third party application.
Social Media Widgets
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org
Personal Information Collected Under Other Circumstances
Groovinads may collect and retain Personal Information from you under other circumstances, such as any communications regarding job postings, service improvements, or support issues. Groovinads will use the same measure of care with this information as we provide to our own private information and office communications.
We may provide your personal information to companies that provide services to help us with our business activities such as marketing our services or managing employee recruitment efforts. These companies are authorized to use your personal information only as necessary to provide these services to us.
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at email@example.com
In certain situations, Groovinads may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors").
Groovinads, generally operates as a processor on behalf of its customers that use the Groovinads's services. Our customer, the controller, determines the purposes and means of the processing of data.
Groovinads operates as a controller in connection with personal data collected from our customers through our website.
Review of Personal Information
Upon request Groovinads will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If you wish to access your Personal Information, please send an email to firstname.lastname@example.org. We will provide you with access to your Personal Information collected on or through our Website so that you can review, correct, update and/or request the deletion of any or all of such information in accordance with applicable laws and regulations. We will respond to your request to access within 30 days.
California privacy rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of Personal Data that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Groovinads via email at email@example.com.
Children’s Online Privacy
Data Controller and Processor
Francisco Borges 2802
Vicente Lopez, Olivos, CP 1636
Buenos Aires, Argentina
Or by email to: firstname.lastname@example.org, or to our data privacy officer at: email@example.com