Privacy Policy - TwinRed

Last modified: 07 December 2020

WELCOME TO OUR PRIVACY POLICY!

This Privacy Policy governs your use of twinred.com, ui.twinred.com, or any other TwinRed site where this Privacy Policy is posted and your interactions with our technologies and services.

We have breaking down this Privacy Policy as follows:

Section 1 provides information on the company controlling your personal data and our contact details.
Section 2 concerns end users visiting third-party websites that have integrated our technology and on which network advertisements are displayed, and that we call our Publisher’s sites (“End User”). If you are an End-User, check this Section to learn more about the processing of your data and the rights you have.
Section 3 concerns the visitors of our site (“Visitor”), as well as the advertisers who has signed up to serve advertisements through our network (“Advertiser”), and the publishers displaying network advertisements on their website (“Publisher”). If you are a Visitor, an Advertiser, or Publisher, check this Section to learn more about the processing of your data and the rights you have.
Section 4 provides other important information about the processing of your data, regardless of whether you are an End-User, Visitor, Advertiser or Publisher.

In all of these instances, whether you are an End-User, Visitor, Advertiser, or Publisher, you may share and we may collect or access some personal information about you. Please be assured that we are fully dedicated to the protection of your personal information.

Because your privacy is so important to us, we provide you with this Privacy Policy, explaining how we collect, use and share your personal information, so that you can make informed choices about the use of your personal information.

Please read this Privacy Policy carefully. By using or interacting with our technologies and services, you agree to be bound by its terms.

You can contact us if you have any question about our privacy practices or about what we are doing with your personal information. We will be happy to provide you any assistance you may need.

1. GENERAL INFORMATION

The following company decides how and why your personal data is processed, and for GDPR purposes is the “Data Controller”:

AdSupply Inc. is a California corporation having its registered address at 9024 W. Olympic Blvd. Beverly Hills, CA 90211, United States of America, and registered with the California Secretary of State under number C3416158.

If you have any comments or questions about this Privacy Policy or generally about our privacy practices, please send an email to support@twinred.com, or to our Data Protection Officer at dpo@twinred.com or via mail to the address indicated below, and we will quickly get back to you. We are always glad to talk about our privacy practices.

AdSupply Inc.
9024 W. Olympic Blvd. Beverly Hills,
CA 90211, United States of America

2. YOUR ARE AN END-USER OF A PUBLISHER’S SITE

2.1 What Personal Data Do We Process?

If you are an Internet user and you are visiting a website where one of our network ad is displayed (i.e. a publisher’s site) and/or interact with the ad, we are collecting and processing some personal information about you.

As used in this Privacy Policy, the terms “personal information” and “personal data” mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

The data we collect and process about you does not reflect your name, email address, address, phone numbers, or other data, which could be used to identify you personally. However, the information listed below could be combined with other data to identify or reveal information about you. It may also allow us to recognize your device over time and across websites. Therefore, it may qualify as personal data under applicable laws.

Please also note that we do not collect and/or process any personal data that could be qualified as sensitive according to the applicable laws (in particular, information concerning racial or ethnic origin, political opinions, religious or philosophical affiliation or beliefs, trade-union membership, health, sex life or sexual orientation, genetic data or biometric data, criminal convictions or alleged commission of an offense), and we do not allow the Publishers/Advertisers to pass such information to us or target End-Users based on such information.

We use cookies and other tracking technologies (such as pixel tags, and unique advertising identifiers) to collect information about your activity, browser, and device. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

The information we collect and/or process about you includes, without limitation:

Device identifiers and related information, including your IP address, User Agent (as defined below), your operating system (and version), your Internet Service Provider, and identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

The term “User Agent” refers to a text (or a string) sent by your browser to every website you connect with, that identifies the type of device you are using (e.g. desktop, mobile or tablet) and the type and version of your browser. Note that your IP address and your User Agent will be combined and anonymized within a short time after the collection, and we will only store the anonymized combination in our records. However, this data might remain in webserver logs that we usually keep 10-14 days for diagnosis purposes.

Location data, as extracted or inferred from your IP address, and including your country, State or region, city, zip code, as the case may be. We also collect your time zone, language, and, if you are in the U.S., the Designated Market Area (“DMA code”).
Information about ads served, viewed or clicked on, including the type of advertisement you interacted with, which advertisement you interacted with, the tracking pixel in the advertisement (if any).

Information that an Advertiser has collected about you and shared with us. When creating an ad campaign, Advertisers can choose to target only a group of End-Users who had a specific behavior that the Advertisers themselves identified (e.g. an End-User who started the sign-up process on the Advertiser’s site, but did not finish it). Note that, in most of the cases, we do not know what is the behavior/criteria used by the Advertisers for their ad campaign. Advertisers are free to use any name or identifier to designate such behavior. We process it as a numeric identifier and do not connect the meaning of the given name anyhow. This naming option is provided to Advertisers to help them in the organization of their ad campaign, so that they can create some tags for specific behaviors or audience type.

2.2 Why Do We Use Your Personal Data?

We use your personal data for the following purposes:

Serve ads and allocate the successful advertisement to a particular business transaction between a Publisher and an Advertiser.
Geographic targeting: we give the option to Advertisers to serve ads based on your location, as inferred from your IP address. We do not collect and process your exact position or address.
Personalized advertising: we give the option to Advertisers to customize ads showed to you based on your device related information (e.g. an Advertiser can decide to set up an ad campaign targeting internet users using android and a specific internet service provider). Advertisers can also choose to target only a group of End-Users with a certain behavior or a specific audience type that the Advertisers themselves identified (e.g. an End-User who started the sign-up process on the Advertiser’s site, but did not finish it).
Reporting on ad campaign and ad performance: reporting to Advertisers and Publishers in the form of aggregated statistics about the effectiveness of online advertising campaigns (e.g. per country, device, or browser type, etc…).
Fraud detection and prevention: identifying fraudulent behavior (e.g. invalid clicks/fake traffic) or other unauthorized or illegal activity on the internet.
Analytics: analyzing campaigns performance and ad display and conduct research and development in order to improve and optimize our services.
Frequency capping: preventing you from seeing the same ad or type of ad too frequently.
Debugging errors in systems
Respond to requests of competent authorities and/or enforce our legal rights

2.3 With Whom Do We Share Your Data?

Entities of our company’s group: we share your personal information with the following companies of our group based in Luxembourg and Hungary as they are helping us to deliver the ad network related services:
- TwinRed Capital S.L., Passeig de Joan de Borbo, 99, 08039 Barcelona, Spain;
- Docler Services Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
- Docler Services S.à r.l., Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
- Ad Supply Holding S.à r.l., Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.

Advertisers/Publishers: we generally only share anonymized data with the Advertisers or Publishers. As an exception, we may share your IP address and User Agent with Advertisers in the specific case where Advertisers are defining their ad campaign using “macros” and requesting this data for fraud detection purpose.
Partner ad networks: we may share a portion of your personal data (i.e. IP address and User Agent) with other third-party ad networks or business partners who are interested in serving End-Users advertisements from their own advertisers. Please note, however, that these “business partners” are not our legal partners, and nothing herein shall be construed as creating a legal partnership.
Service providers: we use carefully selected and trusted third parties, who act as service providers. We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our activity, our third party service providers may regularly change. Such entities mainly belong to the following areas:

Business intelligence and analytics: We use an analytics service provider in order to get a comprehensive view and understanding in relation to campaigns performance and ad display.
Fraud detection and prevention: We use a fraud detection and prevention service provider in order to detect/prevent traffic abnormalities that might corrupt our conversion paths.
Law enforcement agencies or governmental authorities: We may share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our Terms and Conditions, and or any other applicable rules, and/or (d) protect our rights or defend ourselves against any claims.
Business transfers: Your information may be transferred to another entity of our group following some internal reorganization or to another third party entity in case of sale, reorganization, restructuring, merger and/or acquisition or any other disposal whatsoever at group or company level resulting that part (more than 50%) or whole of our business (or related assets) is either directly or indirectly transferred or falling under control of a third party acquirer, provided the latter and/or the other group company in case of internal reorganization operates within same or similar line of business as ours and commits to comply with this Privacy Policy.

2.4 Your Choices and Rights

Opt-out from targeted advertising

You have the right to opt-out from targeted advertising. In such case, Advertisers will not be able to customize their ads based on certain behaviors or audience type and your data will not be shared with third-party ad networks.

If you would like to do so, you can send us an email to dpo@twinred.com and our Support Team will redirect you to a privacy center page where you can confirm your choice.

Important information:

- In order to be able to detect such choice and stop processing your data in the future, we need to store cookies in your browser (opt-out cookies). Considering the very limited personal data we process about you, this is the only way we can prevent any further processing of your data for such purpose.
- This also means that if you delete the cookies from the browser, we will not be able to detect that you opted-out from targeted advertising and we may start again processing your information for such purpose.
- Your opt-out request only applies to the device and browser that you use to confirm your request on our privacy center page. You can visit this page from other devices and browsers if you would like to extend your opt-out request to them.
- The opt out does not block or delete cookies and does not prevent the use of cookies or other technologies for purposes other than selecting ads based on specific behavior (as identified by the Advertisers), and sharing data with third-party ad networks. If you opt out, data may still be collected about your web browsing activities and you will still see advertising. Ads may be selected, for example, based on the content of the web page in which they are shown. If you wish to block or delete cookies altogether, you can use web browser settings to do so.
Other Rights

Depending on your location or residence, you may have specific rights under the applicable laws, notably part or the totality of the rights listed below. If you wish to exercise any of your rights below, please send an email to dpo@twinred.com.

Request data access, data portability and/or right of rectification: Due to the nature of the personal data we collect and process, we do not have sufficient information available to identify you with certainty and confirm that specific personal data relates to you.
Request your data to be deleted: If you no longer want us to use your information, you can request that we erase your personal information. However, despite of your request, we may still retain and use your personal information to the extent necessary to comply with our legal obligations.
We retain anonymized information only for a maximum of ninety (90) days.
Object to the processing of your data in certain circumstances;
Opt out of the sale of your data to third parties;
Not be discriminated against for exercising your rights with respect to your data.

2.5 Information for Residents of European Countries

2.5.1 Legal Basis for the processing

Note that the GDPR requires to fulfill a legal basis to make a data processing lawful.

When we collect and process your data for targeted advertising (including, targeted advertising based on behavior identified by the Advertisers, as well as the transfer of your data to third party ad networks), we rely on your consent.
The Publishers offering space on their site for the placement of targeted ads must first obtain your consent for this purpose, in compliance with the applicable laws and the agreement that we have with them.
If you provided your consent, but you would like to change your mind, you can opt-out from targeted advertising, as explained in Section 2.4 “Your Choices and Rights”.
When we process your data for other purposes, as explained in Section 2.2. “Why Do We Use Your Personal Data?”, we process your data given our legitimate interest in providing our advertising technology services, as well as improving and optimizing such services, except where our interests are overridden by your data-protection interests or your fundamental rights and freedoms.
We may also use your information to respond to requests of competent authorities or given our legitimate interest to establish, exercise or defend legal claims.
In certain cases, we may rely on a legal obligation to process your personal data.

2.5.2. What Are Your Rights Regarding Your Personal Data?

If you wish to exercise any of your rights below, please send an email to dpo@twinred.com.

Our Support Team will provide you with information on actions taken within one month of the date of receipt of your request. In exceptional circumstances, when we face complex or a high number of requests, we may extend this period of response for up to two additional months.

Please note that your rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Data access, data portability and right of rectification: Due to the nature of the personal data we collect and process, we do not have sufficient information available to identify you with certainty and confirm that specific personal data relates to you.

Data erasure: If you no longer want us to use your information, you can request that we erase your personal information by sending an email to dpo@twinred.com. Your request will be sent to our Support Team who will contact you to learn more about your request.

Please note that even though you requested the erasure of your personal information, we may retain and use your personal information to the extent necessary to comply with our legal obligations.

Right to object: We process your data for a variety of reasons. Applicable law entitles you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please note that you may, at any time, opt-out from targeted advertising, as explained in Section 2.4 “Your Choices and Rights”.

Right to restriction of processing: You have the right to request that we stop processing your data, while we resolve any issues (e.g. you have objected to a processing activity based on legitimate interest, you consider that the processing is unlawful, or we have no further need for the data but you require it to establish, exercise, or defend legal claims).
Right to lodge a complaint with a supervisory authority: If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (in particular in the Member State where you live, where your place of work is located, or where an alleged infringement of the GDPR took place).

2.6 Information for California Residents

If you are a California resident, you have certain special rights under the California Consumer Privacy Act (“CCPA”).

Right to “Know” and to Request Deletion: You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.You also have the right to request deletion of personal information we’ve collected or maintain.To exercise these rights please contact us as provided in Section 1 above.We may ask you to provide additional information in order to verify who is making the request. Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.

Your Right to Opt Out: Under CCPA’s broad definition, “personal information” may also include (in addition to names, addresses, and the like) unique identifiers, IP addresses, and even inferences which may be drawn from any of the above. CCPA also defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”Under these broad definitions, certain transfers of information (such as IP addresses, User Agents, and combinations of these) which are necessary to operate our network could arguably be deemed a “sale” of “personal information” under CCPA. You have the right to opt out of this “sale.” For more information on how to opt out, click here.

Personal Information “Sold” or Disclosed: You also have the right to know what categories of personal information we’ve “sold” or disclosed for a business purpose, and the third parties to whom that information was disclosed.In the last 12 months we’ve disclosed the following categories of information to the following parties: (1) IP address and User Agent to our partners ad networks; (2) IP address and User Agent to our Advertisers in the specific case mentioned in Section 2.3; and (3) IP address and User Agent, and information collected by cookies and other technologies, as described above, with our third-party service providers, as necessary for them to assist us with running our business.

Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services.
Right to Use an Authorized Agent: You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section 1 above. In order to verify you have authorized an agent we will require a signed, written authorization from you.

3. YOU ARE A VISITOR OF TWINRED.COM OR UI.TWINRED.COM OR AN ADVERTISER OR PUBLISHER

3.1 You Are a Visitor Of Twinred.com or ui.twinred.com

What personal data do we process?

If you are a Visitor of Twinred.com or ui.twinred.com or any other TwinRed site where this Privacy Policy is posted, we collect and process information about you.

Like many websites, we use cookies and other tracking technologies (such as web beacons, web storage, and unique advertising identifiers, as the case may be) to collect information about your activity, browser, and device. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

The information we collect and process includes your log data and device information: When you visit our site, we temporarily (typically 10-14 days) store log data and information from or about your computer, phone, or other device you use to access or navigate on our site, including your IP address, the date, time and duration of your visit, the hardware, software or internet browser you use, information about your computer’s operating system, the referrer URL, identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

Why do we process your personal data?

We collect and process log data and device information in order to facilitate the use of our site, improve our services, and ensure the security of our systems and the technical administration of the network infrastructure.

We process this information given our legitimate interest in ensuring the smooth running of our site, as well as information, system, and network security.

3.2 You Are an Advertiser or Publisher

What personal data do we process?

Personal information we get when you register on our site or contract with us: when you register on our site or contract with us, we collect personal information about you, including:
- Your identification details: your full name (for billing/payment purpose as the case may be), contact name, vat number, company registration number, job title, company/account name;
- Your contact information: your email address (for billing/payment purpose, as the case may be), contact email address, telephone number, postal address and country, your Skype username.
Personal information we get when you contact TwinRed Support or communicate with us: we collect all information you choose to share with TwinRed Support, such as your personal e-mail, your feedback, comment or request and your conversations with the Support team. More generally, when you communicate with us in any other way, we will collect the information you provide us.
Personal information we get when you are browsing on the Advertiser or Publisher interface: When you visit our site, we temporarily (typically 10-14 days) store log data and information from or about your computer, phone, or other device you use to browse on the Advertiser or Publisher interface.

This includes, without limitation:

- your IP address;
- the date, time and duration of your visit;
- the hardware, software or internet browser you use;
- information about your computer’s operating system (e.g. application version);
- identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
- the website you were referred from to our website (i.e., the referrer URL);
- the type of device you are using.

Transaction information: we process the information you provide us with for payout or payment and invoicing purposes, depending on whether you are an Advertiser or a Publisher, including without limitation bank account numbers and credit or debit card numbers.If you choose to execute the transaction through a virtual account provider (if available), we will not be responsible for the data you provide to this third party to create and manage your virtual account. Please check directly the privacy policy of the virtual account provider if you want to learn more.

Why do we process your personal data?

To open your Advertiser or Publisher account and/or register you as a Publisher/Advertiser in our system: we use the personal data you give us to create and administer your online account and/or register you as an Advertiser or Publisher in our system.

We process this information as it is necessary for the adequate performance of the contract we have with you.

Customer relationship management, reporting on ad campaign/display and communication with you: sharing your personal details with our Support team allows us to respond to any question you might have.

Please note that we may also communicate with you through emails or any other means, if appropriate, in order to report on ad campaign/display or inform you of certain changes regarding our site or of some events/actions, for example, when you successfully register on our site.

We process this information given our legitimate interest in improving our users’ experience and delivering appropriate customer services.

Sending of commercial communications: When you sign up to use our site and services, provided that you give your consent, we will send you commercial emails to keep you up to date with special or new offers related to our services, news about our company or new business opportunities, as the case may be.

You can, of course, unsubscribe from receiving our commercial emails at any time, using a link contained within the emails themselves or using the contact details provided in Section 1. However, this means that you may miss out on special offers and information regarding new services.

Payment and accounting: we use your data for payment/payout and accounting purposes to process transactions and maintain legally required business records.

We process this information, as it is necessary for the adequate performance of the contract we have with you once you register as an Advertiser or Publisher.

Ensure a safe and trustworthy environment: Because we want to create and ensure a safe environment, we use your personal data to detect and prevent fraud and other illegal activities related to the use of our site.

We use your personal information for security purposes and risk assessment, such as to authenticate you on our site and verify your identity.

We process this information given our legitimate interest in ensuring fraud detection and prevention, as well as, information, system, network and cyber security.

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data, such as for accounting purposes, to respond to requests of competent authorities or to establish, exercise or defend legal claims.

3.3 With Whom Do We Share Your Data?

Entities of our company’s group: We share your personal information with the following companies of our group based in Luxembourg and Hungary as they are helping us to deliver the ad network related services:
- TwinRed Capital S.L., Passeig de Joan de Borbo, 99, 08039 Barcelona, Spain;
- Docler Services Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
- Docler Services S.à r.l., Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
- Ad Supply Holding S.à r.l., Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.
Service providers: we use carefully selected and trusted third parties, who act as service providers. We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our activity, our third party service providers we are using may regularly change. Such entities mainly belong to the following areas:

- Business intelligence and analytics
- Fraud detection and prevention
- Customer care/support

As regards www.Twinred.com, we are using WordPress.com, which offers the design, features, and support to our site. To learn more about the data they process under our instructions, please check their privacy policy here.

Payment providers and financial institutions: if you are an Advertiser or a Publisher, in order to process your payment/execute the payout, you may share information with a third party bank or payment processor.

You may receive transactional emails from this party confirming the receipt of your referral fees, including other possible relevant notifications.

If you share information with third parties directly, this Privacy Policy does not govern that information.

We may furthermore share information with relevant financial institutions or payment processors, if we consider it strictly necessary for fraud detection and prevention purposes.

Law enforcement agencies or governmental authorities: We may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our Terms and Conditions, and any other applicable rules, and/or (d) protect our rights or defend ourselves against any claims.
Business transfers: Please also note that your information may be transferred to another entity of our group following some internal reorganization or to another third party entity in case of sale, reorganization, restructuring, merger and/or acquisition or any other disposal whatsoever at group or company level resulting that part (more than 50%) or whole of our business (or related assets) is either directly or indirectly transferred or falling under control of a third party acquirer, provided the latter and/or the other group company in case of internal reorganization operates within same or similar line of business as ours and commits to comply with this Privacy Policy.

3.4 Your Rights

Request data access, data portability
Request that we rectify your data
Request your data to be deleted: If you no longer want us to use your information, you can request that we erase your personal information. However, despite of your request, we may still retain and use your personal information to the extent necessary to comply with our legal obligations and/or for our legitimate business interests.
Object to the processing of your data in certain circumstances;
Right to restriction of the processing;
Not be discriminated against for exercising your rights with respect to your data.

3.5 Information for Residents of European Countries

Based on the GDPR, you have specific rights as regards the processing of your personal data. If you wish to exercise any of your rights below, please send an email to dpo@twinred.com.

Please note that your rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Data access and data portability: You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge. Upon verification of your identity, your request will be sent to our Support Team.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Rectification of inaccurate or incomplete data: You have the right to request that we correct any inaccuracies in your personal data.
Data erasure: If you are a Publisher or Advertiser, we generally retain your personal information for as long as it is necessary for the performance of the contract between you and us and to comply with our legal obligations.

If you no longer want us to use your information, you can request that we erase your personal information. Your request will be sent to our Support team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time.

Please note that if you request the erasure of your personal information:

- We might retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if you are an Advertiser/Publisher, in case we close or suspend your account for fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information shall also be kept available in case of ongoing judicial proceedings/and or investigations.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- In order to protect our site and your personal information from accidental or malicious loss and destruction, we have backup systems. Residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Right to object: We process your data for a variety of reasons, as explained above. Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

Please note that you may, at any time, ask us to stop processing your data for any direct marketing activities.

Right to restriction of processing: You have the right to request that we stop processing your data, while we resolve any issues. Basically, you can restrict the processing of your data in four cases:
- You have contested the fact that the personal data we hold about you is accurate. In this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.
- You have objected to a processing activity based on legitimate interest(s). In this case, you can require the processing operation to be put on hold while we verify the grounds for processing.
- You consider that the processing is unlawful but you request restriction rather than erasure.
- We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

Right to lodge a complaint with a supervisory authority: If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (in particular in the Member State where you live, where your place of work is located, or where an alleged infringement of the GDPR took place).

3.6 Information for California Residents

If you are a California resident, you have certain special rights under the California Consumer Privacy Act (“CCPA”).

Right to “Know” and to Request Deletion: You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.

You also have the right to request deletion of personal information we’ve collected or maintain. Please note, however, that our deletion of your personal information may negatively affect our ability to provide you with services.

To exercise these rights please contact us as provided in Section 1 above.

We may ask you to provide additional information, such as your name, email address, or other basic personal information about you that we already have on file, in order to verify who is making the request. Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.

Personal Information Disclosed: You also have the right to know what categories of personal information we’ve disclosed for a business purpose, and the third parties to whom that information was disclosed.

In the last 12 months, we’ve disclosed the following categories of information to the following parties: the log data and device information, usage information, transaction information, and information on ad campaign/display, as described above, with our third-party service providers as necessary for them to assist us with running our business.

Your Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services.
Your Right to Use an Authorized Agent: You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section 1 above. In order to verify you have authorized an agent we will require a signed, written authorization from you.

4. OTHER IMPORTANT INFORMATION

4.1 How Do We Protect Your Personal Data?

Whether you are an End User, Visitor, Advertiser, or Publisher, we implement commercially reasonable security measures to protect your personal information against unauthorized access, modification, disclosure or deletion, including without limitation firewalls, network segmentation, and written confidentiality agreements with our employees and agents.

As regards the data of the End Users of our Publishers’ sites, we have implemented a highly secure technology, which anonymizes their IP address and User Agent in a very short time after collection.

We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our site and the entire IT infrastructure related to it are updated against the latest network security vulnerabilities. We periodically test our IT systems, including penetration tests.

4.2 Children’s Privacy

Our site and services are not intended for use by children under the age of 18, and we do not knowingly collect personal information from such children.

If we become aware that we have unknowingly collected personal information from a child under the age of 18 through twinred.com, we will make all reasonable efforts to delete such information from our database. If you become aware that we have unknowingly collected personal information from a child under the age of 18, please contact us as provided in Section 1 above.

Please note, however, that this section only applies to users of our site and services, and we have no way of monitoring the ages of End Users who interact with our network advertisements.

4.3 How Do We Transfer Your Personal Data Outside of the European Economic Area?

As some End-Users, Visitors, Advertisers and Publishers are located in the European Economic Area (“EEA”), we comply with GDPR. If you want to learn more about GDPR, please visit: EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC).

In case we need to transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. When needed, we will utilize the Standard Contractual Clauses approved by the European Commission. For more information, see here.

4.4 Changes To This Privacy Policy

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the relevant site and/or contact you using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force.

Your continued use of our site or services from that day on will be subject to the new Privacy Policy.