Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Important information and who we are
We are AdInMo Ltd. We are a company incorporated and registered in Scotland, United Kingdom, with company number SC648449. Our registered office address is 5th Floor, 125 Princes Street, Edinburgh, EH2 4AD.
When we refer to “we”, “us” or ”our” in this policy, we are referring to AdInMo Ltd. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.
We use the following definitions in this policy to cover the different categories of individuals we interact with via our Site and Services:
- Client: Means a games publisher, developers or other third party entity which has entered into a contract with us for any of our Services;
- Registered User: Means an individual employee, contractor or agent of a Client who is authorised to register for use the Service by that Client; and
- User: Means any person accessing our Site.
Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
Third-party advertising networks
Our apps may include third-party advertising networks. These networks determine independently how to use your information, so review their linked privacy policies to learn more.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions:You may give us your personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when creating an account with us and when you request marketing communications to be sent to you.
- Automated technologies or interactions: As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.
- Third parties or publicly available sources:We may receive personal data about you from various third parties and public sources. For example, analytics providers such as Google.
Information we collect from you
We may collect and process the following data about you:
- Account Data:Is the information provided to create an account and log-in details for our Services.
- Contact Data: Is the information you provide us with when forms on our Site are completed including name, last name, name, email address and company.
- Marketing Data: If you consent to receiving updates about our platform, new products and other changes we may use your name and email address to send you such updates by email.
- Technical Data:Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
- Usage Data:Means information about how your use of the Site and Services.
How do we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract for services we are about to enter into or have entered into with you (i.e. when you purchase something from us).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal or regulatory obligation.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|To respond to your enquiries||Contact data||Consent (as you are requesting us to respond to you)
Necessary for our legitimate interests (to respond to enquiries from customers and potential customers)
|To enable Registered Users to access the Services||Account data||Performance of a contract with you|
|To send you marketing emails||Marketing data||Consent
Legitimate interests (to market to network of customers and contacts)
|To personalise our Site and improve user experience for the Site and Services||Technical data
|Legitimate interests (to improve customer interactions)|
|To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Contact data
|Necessary for our legitimate interests (for running our business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Performance of a contract with you
Disclosure of your information
We may have to share your personal information with the following third parties:
- External third-party service providers acting as processors who provide the following services:
- Web hosting;
- Metrics and analytics; and
- Marketing, mailing and survey third party tool providers
- Please note this includes the international service providers listed below in International transfers.
- Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors, controllers or joint controllers who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If AdInMo Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- If we use certain service providers based outside of the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- In any other case, we will obtain your explicit consent before any transfer takes place.
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. The table below sets out details of transfers to such third parties and the relevant safeguards.
|SurveyMonkey||Customer feedback and survey||Privacy Shield|
|Mailshake||Marketing automation||Privacy Shield|
|Mailchimp||Marketing automation||Privacy Shield|
|PayPal||Credit Card billing||Privacy Shield|
|HubSpot||Customer CRM||Privacy Shield|
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures in accordance with industry best practice to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we store your personal data for
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We normally delete personal identifiable information we hold on you within 30 days of the end of the service but in some circumstances you can ask us to delete your data sooner: see Deleting personal data below for further information.
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
What are cookies?
A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.
What cookies do we use?
The cookies that we use fall into the following categories:
- Strictly necessary cookies:These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site.
- Analytical/performance cookies:They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that Users are finding what they are looking for easily.
- Functionality cookies:These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences.
- Targeting cookies:These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We use various types of cookies (including some that we place and others which we permit third parties to place on our site) for a number of purposes. The information collected by cookies allows us to monitor how many people are using our services and their interactions with other services. Cookies are also used to facilitate a user’s log-in, as navigation aids, and as session timers, and to restrict underage use of our tools and services.
If for any reason you do not want us to track your use of our site using cookies, you can opt out of this using your browser settings and can also select the option “Do Not Track” (for more information please refer to your browser).
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
To find out how to manage cookies on popular browsers:
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
We use web beacons to collect information about the use of our services. The information collected by web beacons allows us to monitor how many people are using our services, how many people open our e-mails, and determine for what purposes these actions are being taken. Our web beacons are not used to track activity outside of our services.
You can find more information about the individual cookies we use and the purposes for which we use them below:
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
The cookie expires 24 months from the date that it was set.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Google AdWords remarketing service is provided by Google Inc. The DoubleClick by Google cookie analyzes audience to improve website design and content for conversion tracking and retargeting. The cookie expires 24 months from the date that it was set.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read below to find out more about these rights.
If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Access to your information
You have the right to ask for a copy of the information which we hold on you (commonly known as a ‘data subject access request’).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Correcting personal data
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
Deleting personal data
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objecting to processing
You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction of processing
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Transferring your personal data
In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Review by an independent authority
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.
This version was last updated on 23/05/2018.
Historic version of this policy can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Protection Officer at firstname.lastname@example.org