Privacy policy

GENERAL INFORMATION

Users personal data, including that of registered users („User”) of the platform available at https://ads4media.online/ („Service”) is administrated by Grupa Tipmedia Spółka z ograniczoną odpowiedzialnością based in Lublin, 6 Cyprysowa Street, 20-224 Lublin, Poland entered into the Register of Entrepreneurs of the National Court Register kept by the District Court in Lublin-Wschód in Lublin with its main office based in Świdnik, VI Commercial Division of the National Court Register under KRS number 0000583772, NIP: 9462653563, share capital amounting to PLN 876,000.00 ("Administrator"). 

Contact with the Administrator in matters related to the processing of personal data is possible via e-mail to the following address: [email protected] or by post to the Administrator's address.

PURPOSES OF PERSONAL DATA PROCESSING

The Administrator processes the personal data of Users who:

1. are registered and use the Service in grounds of:

• providing services by means in the field inc. providing access to the website, registering the user’s account, processing payments, and making settlements- the legal basis for processing is the necessity of processing to perform the concluded agreement with the subject of personal data (Art. 6.1.b/ GDPR) and the consent of the data subject relate to (Art. 6.1.a/ GDPR) in case of voluntarily provided data,
• processing complaints and maintain accounting records related to settlements under agreement- the legal basis for processing is the necessity to fulfil the legal obligation incumbent on the Administrator (Art. 6.1.c/ GDPR),
• analytical and statistical record- the legal basis for processing is the Administrator’s legitimate interest (Art. 6.1.f/ GDPR), consisting in the conducting analyses of User’s activity and preferences to improve the functionalities and service provided,
• possible establishment, inquiry or defense against claims- the legal basis for processing is the legitimate interest of the Administrator (Art. 6.1.f/ GDPR) consisting in the protection of User’s rights,

2. use the Service without registering a User’s account in grounds of:

• analytical and statistical record- the legal basis for processing is the Administrator’s legitimate interest (Art. 6.1.f/ GDPR), consisting in the conducting analyses of User’s activity and preferences to improve the functionalities and service provided, 
• possible establishment, inquiry or defense against claims- the legal basis for processing is the legitimate interest of the Administrator (Art. 6.1.f/ GDPR) consisting in the protection of User’s rights,

3. contact the Administrator:

• to obtain an offer of services provided by the Administrator- the legal basis for the processing is the Administrator’s legitimate interest in marketing its own services (Art. 6.1.f/ GDPR) in connection with the consent given, 
• to implement the User’s rights granted to him under the law- the legal basis is the necessity to fulfil the legal obligations incumbent on the Administrator (Art. 6.1.c/ GDPR),
• in matters other than those indicated in point (a) and (b) above- the basis for processing is the Administrator’s legitimate interest in handing inquiries from Users to the Administrator (Art. 6.1.f/ GDPR).

4. Have agreed to receive commercial information: 

• to send ordered commercial information- the legal basis for the processing is the Administrator’s legitimate interest in marketing its own services (Art. 6.1.f/ GDPR) in connection with the consent given, 
• analytical and statistical record- the legal basis for processing is the Administrator’s legitimate interest (Art.6.1. f/ GDPR), consisting in the conducting analyses of User’s activity and preferences to improve the functionalities and service provided,
• possible establishment, inquiry or defense against claims- the legal basis for processing is the legitimate interest of the Administrator (Art. 6.1.f/ GDPR) consisting in the protection of User’s rights.

The Administrator also processes Users’ personal data for marketing purposes by displaying advertisements regarding the Administrator’s services and products- the basis for data processing is the implementation of the Administrator’s legitimate interest (art. 6.1.f/ GDPR) in the form of marketing of own services. 

THE VOLUNTARY PROVISION OF PERSONAL DATA

Providing your personal data is always voluntary. At the same time, however, it is necessary for the purpose of communication with you, as well as for the proper performance of the agreement by the Administrator.

Consent to processing personal data for marketing and contact purposes are entirely voluntary and in no way affects the provision of services by the Administrator. However, if you do not agree, the Administrator will not be able to contact you to present an offer.

RECIPIENTS OF PERSONAL DATA

1. The Administrator, as part of the processing purposes specified in this Privacy Policy, provides Users’ personal data to recipients of personal data:

• service maintenance and development providers, hosting providers,
• e-mail providers,
• providers of e-mail and SMS/ MMS sending programs,
• the website analysing tools and User activities providers,
• suppliers of invoicing system,
• customer service entities,
• banks together with financial and accounting service entities,
• payment intermediaries,
• entities providing legal services to the Administrator.

2. The third parties mentioned above are obligated under relevant agreements to use the data entrusted to them solely for the purposes indicated by the Administrator. These entities are also obligated to adequately secure the personal data and keep it confidential.

3. Users’ personal data may be made available to authorized entities, including competent judicial authorities under applicable law.

4. The personal data of Users using the Platform as registrated Users who are advertisers or publishers will be shared by the Administrator with the other party, respectively, to enable the execution of the agreement between the advertiser and the publisher.

DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

To provide services, the Administrator uses tools provided by entities that are located outside the European Economic Area, and some of the suppliers may transfer data outside the above- mentioned territory:

1. Meta Platforms Inc. based in California, USA- the entity responsible for the activities of the Administrator’s fan page and the provider of the tool for conducting advertising campaigns. Information on privacy standards:  https://www.facebook.com/privacy/explanation. Meta Platforms Inc. has stated that it has implemented standard contractual clauses, which you can read about here: https://www.facebook.com/business/help/336550838147603.

2. Google LLC based in California, USA- Website traffic analysis tool provider. Information on privacy standards: https://policies.google.com/privacy?hl=pl. Google has announced that it has implemented new standard contractual clauses, which you can read about here:

• https://support.google.com/analytics/answer/9012600?utm_source=awfe&utm_medium=email&utm_campaign=20175128
• https://business.safety.google/adscontrollerterms/
• https://business.safety.google/adsprocessorterms/.

3. Twilio INC based in San Francisco, USA- provider of a tool that enables the sending of information, including commercial information to users in the form of e-mail and SMS/ MMS messages. Information on privacy standards: https://www.twilio.com/legal/privacy. Twilio has announced that it has implemented new standard contractual clauses, which you can read about here: https://www.twilio.com/gdpr.

4. ActiveCampaign LLC based in Chicago, USA- provider of a tool that enables the sending of information, including commercial information to users in the form of e-mail and SMS/ MMS messages. ActiveCampaign has announced that it has implemented new standard contractual clauses, which you can read about here: https://www.activecampaign.com/legal/gdpr-updates/privacy-shield.

5. Ahrefs Pte. Ltd. Based in Singapore, Singapore- provider of the Website analysis tool in terms of organic traffic. More information on data processing by the provider: https://ahrefs.com/privacy-policy.

6. OpenPhone Technologies INC based in San Francisco, USA- a service provider that allows you to make phone calls using the Internet network infrastructure. Information on privacy standards: https://www.openphone.com/privacy.

Any transfer of personal data outside the European Economic Area by the Administrator shall be made in accordance with data protection legislation and solely for the purposes and within the scope of the relevant purpose.

PERSONAL DATA WILL BE PROCESSED FOR THE FOLLOWING PERIODS OF TIME:

Users’ personal data:

1. using the Administrator’s electronic services (entering into an agreement with the Administrator) are processed for the whole time of the service use by the User and up to 3 years after its termination,
2. in case of accounting and tax obligations of the Administrator they are stored for no less than 5 years due to tax and accounting requirements,
3. processed based on the legitimate interest of the Administrator are processed for the duration of the legitimate interest, but no longer until the User objects to such processing,
4. processed based on consent are processed if the purpose of consent exists or until the consent is withdrawn by the User.

In the event of a dispute between the Administrator and the User, or the existence of a potential dispute, the Administrator may retain the Users’ personal data, beyond the periods indicated above, if this is necessary to protect the Administrator against claims and/or the assertion of rights by the Administrator.

AUTOMATED DECISION- MAKING AND PROFILING

The User’s personal data shall not be processed in an automated manner, so that any decision regarding the User could be made because of such automated processing. Users’ personal data may be profiled to adapt the content and personalize the offer addressed to the User. This profiling will not have any negative impact on the rights and freedoms of the User.

THE RIGHTS OF DATA SUBJECTS

1. Users whose personal data is processed by the Administrator has the right to:

• access to their personal data,
• rectify them if they are incomplete or insufficient,
• processing restrictions,
• request their transfer or removal,
• lodge a complaint to the President of the Personal Data Office if the User considers that the processing of his personal data violates the provisions of the GDPR.

2. If personal data is processed based on the User’s consent, the User may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on it until the consent is withdrawn.

3. The User has the right to object at any time to the processing of his data for direct marketing purposes including profiling, where the processing is carried out in connection with the legitimate interest of the Administrator.

4. The User may object at any time to the processing of his data for reasons related to his situation in cases where the legal basis for data processing is the Administrator’s legitimate interest.

5. To use any of the above rights, please send an e-mail to: [email protected] or by post to the Administrator’s address: Grupa Tipmedia Spółka z ograniczoną odpowiedzialnością based in Lublin, 6 Cyprysowa Street, 20-224 Lublin, Poland.

COOKIES

1. The Administrator uses cookies on the Website. Cookies are text files saved and stored by a web browser or directly in the Users' end equipment, i.e., computers and mobile devices. Cookies are saved during the first visit of a User to the Website and allow to recognize them during subsequent visits.

2. Cookies contain information about the User's device, the time of storage on the User's device and a unique number. Cookies may also constitute personal data of the User.

3. The platform uses two main types of cookies: session cookies and persistent cookies. Session files are temporary files that are stored in the User's end equipment until logging off, leaving the Service, or switching off the software (web browser). Persistent files are stored in the User's end equipment for the time specified in the parameters of cookies or until they are removed by the User from the end equipment.

4. The Administrator uses the necessary cookies for the proper functioning of the Website, including cookies for:

• a. to correctly display the content of the Website,
• b. maintenance of a session of a logged-in User,
• c. maintenance of security and integrity of the Website,
• d. creation of anonymous statistics which help to understand how  

Users employ the Website, which directly influences improvement of its structure and content.

5. Within the Website the Administrator may also use other cookies based on the User's consent, such as:

• Functional cookies to make the use of the Website more convenient and to personalise settings to remember the User's choices during use of the Website, including choice of language.
• Facebook Pixel provided by Meta Platforms Inc, 1601 S. California Ave. Palo Alto, CA 94304, USA, used for advertising purposes, including the implementation of advertising campaigns, remarketing and analytical and statistical activities.
  Facebook may combine the information collected within the Facebook Pixel with other information about the User collected during his use of Facebook and use it for its own purposes. The Administrator has no control over these activities. For more about Meta Platforms Inc.'s activities, please see the privacy policy: https://www.facebook.com/privacy/explanation.
• Google Analytics provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA - for the purpose of creating and maintaining statistics for the Website and analysing User activities on the Website.

6. The default settings of browsers allow saving and storing cookies on the User's device. The User has the right to decide about the access of cookies to his end device through the settings of his web browser. Leaving the settings concerning cookies unchanged by the User means that he agrees to placing text files of the cookie type on the User's device. Users can change their cookie settings at any time. Detailed information is available in the settings of a given web browser:

• Mozilla Firefox: www.support.mozilla.org/pl/kb/ciasteczka 
• Internet Explorer: www.support.microsoft.com/kb/278835/pl 
• Google Chrome: http://www.support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
• Safari: www.safari.helpmax.net/pl/oszczedzanie-czasu/blokowanie-zawartosci/ 

SERVER LOGS

1. The use of the Service relates to sending requests to the server on which the Service is stored. Each query sent to the server is recorded in server logs, which are saved and stored on the server.

2.  Logs include i.a. User's IP address, date and time of the server, information about the Internet browser and operating system used by the User.

3. The data saved in server logs is not associated with users using the Server and are not used by the Administrator to identify Users.

4.  Server logs are only an auxiliary material used to administer the Server and their content is not disclosed to anyone except those authorized to administer the Server.

This privacy policy is effective from 19 April 2022.