PRIVACY POLICY - JustPremium

PRIVACY POLICY

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INTRODUCTION

JustPremium and its subsidiaries (“we”, “us” “our”) view privacy and the protection of personal data as an important element of the services we provide. We have prepared this Privacy Policy so that you can become familiar with how we collect, use and share information we receive and collect about you. We receive such information on you especially through our services and websites (collectively “Services”). We may receive and process information about you as customer of our Services, or as an end user, when you visit our clients’ websites, mobile applications, media players or other properties. In so far as we process your personal data, Dutch data protection law is applicable and JustPremium shall comply with requirements arising from this. We may change this Privacy Policy from time to time. Please check the Privacy Policy regularly for updates. For more information, please see “Nature of and Changes to the Privacy Policy” below.

What data we process on you

  1.   Personal Data

With “personal data” we mean any information that may identify you as an individual.

  1.  Personal Data On Clients

The personal data we process may include, among others, the following information on our clients:

  • Company name;
  • Name;
  • Contact details (such as e-mail address, telephone number and address);
    Payment information (such as bank details);
  • Correspondence (such as emails); and
  • other information on you relating to, or derived from the use and provision of the Services, and/or your customer relationship or other business with us.

We collect or receive personal data through, among others, JustPremium.com, our other websites, our analytics dashboard for publisher clients, our software applications, social pages, as well as email and other communication channels.

Additionally, we may receive personal data through our advertising Services and technologies used by our publisher clients and other third parties on their websites and other digital properties across the Internet. We may also update and supplement personal data with information provided by third parties in order to improve the Services.

  1.  Personal Data On Individuals Who Visit Our Clients’ Properties

What is said above of processing personal data on our clients may in some situations apply also to individuals who are shown advertising as a result of our technology when these end users visit our clients’ websites, mobile applications, media players or other properties.. We may process the following information on the end user which, in a particular context, may be considered as personal data:

  • your IP-address;
  • a unique user ID;
  • browser type;
  • visited URL;
  • session ID; and
  • time stamp.
  1.  Usage Data

We may collect and process technical and log data such as information sent by your browser when you are visiting our websites or those of our clients. Although technical data does not necessarily aim to recognize you, due to its contents, in practice, you can sometimes be recognized from it. In such situations, these data can also be seen as personal data.

When you use or access our Services or third-party sites, or properties using the Services, we may collect, among others, the following data: the URL of the site from which you came, the pages visited, the site to which you are going, Internet protocol (IP) address of the device you use, the device type, time of webpage visit, webpages visited, time spent on each webpage of the website, and the type of operating system used in the devices used to access the Services, type and version of your browser, date and time an ad was served, clicks on ads, and other traffic data.

We may collect this information in a variety of ways including through your browser or device, mobile advertiser identifier and your IP address. We may also use cookies and other tools, such as pixel tags, web beacons, and other local shared objects, for automatic data collection.

We may use third party service providers, such as Google Analytics, to collect and process technical data on our behalf.

Cookies are pieces of information stored directly on the computer that you are using. Although cookies are a commonly used technology, they vary significantly by features and use. You may control the use of cookies by changing your browser settings and the setting of other programs that use cookies (e.g. the settings of your Adobe Flash Player). For more information about cookies generally, including how to see what cookies have been set on your device and how to control and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

  1.  Location Data

JustPremium may collect and process location data which may identify your current or past location. Such data is processed in order to provide and develop location based Services, and may include information such as your IP-based location or device-based location data. Such device-based data may rely on, for example, the location of Wi-Fi networks, GPS signals, or similar technologies.

When processing location data, JustPremium, or a company acting on our behalf, will always ask for your necessary consent and abide by it.

  1.  Why We Process Data On You

When it comes to the data we process about clients, we process data on you especially in order to host, provide, maintain, develop and improve current and future Services and your customer relationship, as necessary from time to time. Such actions may include sending and directing marketing and other communication to you, and carrying out market research.

When it comes to the data we process about end users who visit our clients’ properties, we process data to be able to deliver our Services to our clients and to calculate payments for this and to monitor and improve the effectiveness of these Services (e.g. by keeping track of what advertisements are shown to a particular user)

Data processing may also be necessary to prevent and investigate fraud and other misuses.

In limited situations, we may process personal data on you for other purposes as well. Such processing may be necessary, for example, due to a legal obligation or public authority request; in order to protect our rights; or to allow us to pursue available remedies or limit sustainable damages.

We keep data only as long as necessary for us to fulfill the purposes described in this Privacy Policy. Once information is no longer necessary, we delete it as soon as possible.

  1.  How we Disclose and Transfer Data On You

We may regularly disclose personal data on you among our subsidiaries and affiliates for the purposes described in this Privacy Policy. In such situations, JustPremium is the party responsible for the management of the personal information that we use jointly with our affiliates. JustPremium may also disclose data to other third parties in limited situations. We do not disclose data to other third parties without careful consideration, and not without you being informed by us or a company acting on our behalf.

In addition to disclosing personal data, we may disclose pseudonym data, and aggregated or other anonymous data to third parties, especially in the following situations:

  • To our publisher partners to allow them to analyze the effectiveness and performance of our Services and to offer targeted ad inventory to our advertiser clients; and
  • To our advertiser clients to allow them to make decisions regarding buying advertising inventory on our publisher clients’ websites and applications, and to analyze the effectiveness and performance of their advertising campaigns via our Services.

We may store and process your personal data in any country where we have facilities, employees, and/or service providers. Such countries may include the United States and other countries outside the European Union. We will ensure that any transfers of personal data to countries outside the European Union are subject to safeguards to ensure an adequate level of protection as required under European law.

  1.  Your Rights

As a client or end user whose personal data we process, you have the right to receive information on how we process data on you. Such information is provided in this Privacy Policy. In addition, you have the right to:

– know what personally identifiable data we hold about you;
– request that incomplete, incorrect, outdated, or unnecessary personal data is corrected, deleted, or updated; and
– opt out of receiving direct marketing communications from us.

If you would like to access or correct data on you, or opt out of direct marketing, please contact us at privacy@JustPremium.com. You can also opt out of marketing communications that you may receive from us, such as e-mail messages and SMS-messages, by using the unsubscribe function included in all of our marketing messages.

Please note that we will need sufficient information from you to establish your identity, and that we may charge a small processing fee if less than a year has passed since your last inquiry relating to accessing personal data we hold on you.

  1.  Opting Out Of Behavioral Advertising

JustPremium and our clients may use behavioral elements in our Services, such as behavioral advertising to end users, in order to provide more relevant services and content to you. Such customized content may be tailored to you based on information which is generated on you by combining previously collected data. To the extent this is done through the use of tracking cookies JustPremium or a company acting on its behalf will first ask your consent.

Some of our publisher clients have their own mechanisms to opt-out or withdraw your consent that are linked to their sites or their online-posted privacy policies. You should review the privacy policies of those companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company, or multiple companies.

  1.  Data Security

The security of personal data is important to us. We seek to use reasonable organizational, technical and administrative measures to protect your personal data within our organization and secure your personal data against unauthorized access, accidental or unlawful destruction, manipulation, disclosure and transfer and other unlawful processing.

  1.  Third Party Activities

This Privacy Policy applies only to personal data processing carried out by JustPremium. The Privacy Policy does not address and we are not responsible for, the privacy, data or other practices of any third parties, including our clients, advertisers, demand or supply side providers, vendors or any other third party operating any site or service that you may encounter in connection to the Services. We encourage you to carefully familiarize yourself with privacy policies applicable to any third party operated websites and/or services, including any third-party website containing our Services. If our Services (or a link to our Services) are included on a third party website it does not mean that we have given an endorsement of such site or service.

  1.  Nature of And Changes to the Privacy Policy

From time to time we may change this Privacy Policy. You can tell when changes have been made to the Privacy Policy by referring to the Last Updated legend on top of this page. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. If you continue to use the Services following any changes to this Privacy Policy, you accept any such changes we have made.

  1.  Questions or Concerns

If you have any questions regarding this Privacy Policy or JustPremium’s privacy practices, please contact us via e-mail at privacy@JustPremium.com or by mail at:

JustPremium BV
Stationsplein NO 410
1117 CL  Schiphol Oost
The Netherlands

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