Last Updated: January 30, 2023

Introduction

This privacy policy (“Privacy Policy“) provides you with details of our practices of processing data from our clients (“Users“, “Data Subject” or “You“) when You access our websites and/or use our services (as provided below). This Privacy Policy forms part of Your agreement with us, when You access our website, available www.explorads.media or any subdomain or website that links to this Policy, (the “Site” or “Website”), or using the ExplorAds web platform (“ExplorAds”, “web platform” or “Platform”) (each individually, or jointly with the Site and Product, the “Services“).  

Your use of our Platform does not involve submitting Personal Data unless You voluntarily choose to provide us with such information. Our Platform is available to relevant users (publishers and advertisers), and certain functionalities may require registration and submission of certain personal data, as described in this Privacy Policy.

This Privacy Policy was designed with the EU General Data Protection Regulation (GDPR). However, given the country of Your residency, other rules may apply to Your Personal Data. If You are a resident of California, we advise You to refer to our notice for California residents below.

The purpose of this Privacy Policy (this “Policy”) is to inform You of regarding the use of Personal Data within ExplorAds as well as those affiliated with us, including data processors, sub-processors and third-party partners. This Policy shall also provide You information regarding how to manage certain data collected about You.

We encourage You to review this Policy from time to time for the latest information on our privacy practices. The last revision practices of our Policy will be reflected in the “last updated” heading.

Definitions:

• Applicable Privacy Laws means any applicable privacy or other law to the extent applicable to our operation, including the California Privacy Right Act of 2020, Cal. Civ. Code §§ 1798.100 et. Seq, (CPRA) to the extent applicable; the General Data Protection Regulation (EU) 2016/679 (GDPR); European Union Member State laws, rules and guidelines implementing or supplementing the GDPR, as amended from time to time and to the extent applicable to our Company’s operation and our Services.
• Clients– Our primary clients are Advertisers or Publishers who utilize the Platform to create, edit and maintain advertising campaigns or to sell advertising placements, including individuals who receive or otherwise interact with the Platform and advertisement Services users (“User(s)“).
• Data Subject– The person about whom Personal Data relates. This could be Clients or a User.
• Personal Data refers to information about a living individual, which means that they can be identified (a) from that data, or (b) from that data and any other information which is, or could in the future, come into the possession of the data controller, and as defined under the Applicable Privacy Laws. Also see Special Categories of Personal Data.
• Data Controller refers to the person, organisation, public authority, agency, or other body who, either alone or with others, determines the purposes for which and the manner in which any Personal Data is to be processed, and defines the controls required for such processing.
• Data Processor refers to any person or organisation (other than an employee of the Data Controller) who undertakes the processing of Personal Data on behalf of the Data Controller.
• Processing refers to any operation which is performed upon or applied to Personal Data, whether undertaken manually or by automated means, including its acquisition, organisation, storage, retrieval, consultation, amendment, availability, disclosure, erasure, or destruction.
• Subprocessor shall mean any entity appointed by us or by one of our sub-processors, such as our vendors, to Process Personal Data on our behalf or on behalf of that sub-processor, excluding any employee of ExplorAds or of our sub-processor or of any such appointed person but including any contractor or affiliate of the foregoing.
• The terms “Controller“, “Processor“, “Sub-Processor”, “Data Subject“, “Personal Data“, “Processing” (and/or “Process“), “Personal Data Breach”, the “Union”, “Member State” and “Special Categories of Personal Data” shall have the meanings given under the GDPR. The terms “Business”, “Business Purpose”, “Consumer” and “Service Provider” or “Contractor” shall have the same meaning as in the CPRA. To the extent that CPRA applies, the term “Controller” shall also mean “Business”, and “Processor” shall also mean “Service Provider”.

Data Protection Roles

Data Processer: Concerning our Platform and the Services we provide to our Clients, we are the Data Processor, as we process certain data, as provided below.

Data Controller: ExplorAds is the Data Controller of Your Personal Data collected on visitors in our webite and our Client’s employees and represnetatives.

Our contact details:

ExplorAds Ltd

2 Filiou Zannetou St.

3021 Limassol Cyprus

privacy@explorads.media

Personal Data

Personal Data is information that is associated with an individual and enables that individual User to be singled out. Through the use of ad tags and cookies we collect information about You. Typically, the information obtained does not identify You directly (i.e. by name or email address), however, the information may indirectly identify Your device or geolocate You for purposes of delivering targeted advertisements. Under GDPR, some information transmitted by Cookies and Tags including Log Data are considered Personal Data.

What Personal Data We Collect?

We store certain (insensitive) Personal Data on You to register and log in the Platform and use our Services. We may receive data from third parties such as analytics providers (see below ‘Disclosures of Your Personal Data to Third Parties’). 

• Contact details – We process our Client’s and Users’ contact details (such as name, email address, or phone number) in case You submitted those to us when You contact us, open an account with us, when subscribing to our mailing list or when reaching out to our support services, as further described below. We process this data for communicating with You and providing our services.
• Signing Up & Registration information to our Platform – Your first and last name, mailing address, phone number, email address, and other similar contact details. We process this data for the purposes of operating the Platform; communicating with You; record keeping and for the establishment; pursuance or defense of legal claims.
• Information processed relating to Clients, Users and advertising (Device and Connection Information) Details of Your IP (Internet Protocol) Address, geo-location, RTB protocols (e.g., IFA), User-Agent and activity including pages accessed, including URLs of websites or names of applications accessed. The details of Users’ device(s) and the context of where it is seen, as it relates to URLs and applications, are essential for general ad targeting advertising. These elements of a User’s browser or device are available for targeting but are not made available to target a User individually. Where ads may be targeted directly to a User – commonly called “retargeting”, in service of an advertiser or merchant whose website or app a User may have interacted with previously, clear and informed consent will be collected by the Clients before such retargeting techniques will be activated.
• Purchasing Services – to purchase Services from us, You will be asked to provide Your contact information, such as Your full name, email address, billing information, and any other purchase-related information.
• Technical/Access information– Details including Your IP (Internet Protocol) Address, User’s activity including pages accessed, information entered are stored for fraud prevention and security auditing.
• Usage information: about the manner in which You use the Website and the Platform that may include connectivity, technical and aggregated usage data, IP addresses, device data (such as type, OS, device ID, browser version, locale and language settings used), approximate geolocation.
• Raw Data. For statistical and operating means, we may collect and process raw data from our Clients’ requests obtained during RTB auctions. When our Client uses our Services, we process only their statistical tracking information, which contains non-identifiable data as provided by our Clients’ use of our Product and Services as Data Controllers (State-level geolocation only). We also process raw data from requests obtained during RTB. Nevertheless, we make efforts to ensure our sub-processors use appropriate technical and organizational measures to secure the protection and retention of Data Subjects.
• Any other Personal Data that You choose to send to us

We use our Users and Client’s (including End Users) Personal Data for the purposes we described next to each data type above, and for the following purposes: 

• Providing our Services and administering and operating our Platform;
• to enabe and support Your use of the services available on our Platform;
• for business development and research and to test out features or additional services;
• To provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information) ;
• To provide communications, marketing, and advertising via the Client’s Platform;
• To provide reporting and analytics;
• To provide troubleshooting, support services, or to answer questions;
• To help Clients integrate with third party publishers and advertiser platforms via our Platform;
• Security and Fraud Prevention. To protect our Users and Clients and to prevent fraud. To provide troubleshooting, support services, or to answer questions;
• Open an account for You, manage it and support it;
• Communicate with You and our Clients. To respond to communications, reach out to our Users and Client’s about their transactions or account, market our Products and Services, provide other relevant information, or request information or feedback. From time to time, We may use Your Personal Data to send important notices, such as communications about changes to our terms, conditions, and policies;
• Comply with Law.To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request and to pursue the following legitimate interests, either for ourselves, our Clients, or other third parties. If we need to do so to establish, exercise, protect or defend our contracts or legal rights, or the rights of others including our employees and affiliates, or detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, we may share Personal Datawith investigators, advisors, consultants or law enforcement authorities.
• If it is in our legitimate interests, for business development and marketing purposes:
  • We may use Your Personal Data to provide You with marketing information about products or services which we think would be of interest to You. These may be sent by email, a text message, or any other available channels, in some circumstances, we may telephone You to explain this information to You.
  • We take care to ensure that our marketing activities comply with all applicable legal requirements and applicable privacy laws. This mean that we ask, and You hereby consent that we send You marketing materials.

In all cases, You can opt-out of receiving marketing communications, at any time. You can do this by clicking on the “unsubscribe” link in any marketing email or by contacting us using the details set out at the end of this Privacy Policy.

Please note that, even if You opt-out of receiving marketing messages, we may still send You communications in connection with the services we provide to You.

The Personal Data we collect and process, as outlined above, is necessary for secure account access and for securing the data systems of the Platform. We will not sell our Clients and Your Personal Data or otherwise transmitte it for commercial usage. We do not intend to process any sensitive data about You.

Your Rights as a Resident of the European Economic Area

If You are located in the European Economic Area (“EEA”), You have certain rights with respect to Your Personal Data, including:

•     the right to be informed
•     the right of access
•     the right to rectification
•     the right to erasure 
•     the right to restrict processing
•     the right to object to processing
•     the rights in relation to automated decision making and profiling.

If You seek to withdraw the consent as the User of our Platform please contact directly to our Client. If You are our Client please contact us at: contact@explorads.com.

Note, that on rare occasions, the data collected and processed until the consent is withdrawn might have to be further processed due to legal requirements of validating the safety and efficacy of the device and the obligation to report adverse events, if any.

You will not have to pay a fee to access Your Personal Data (or exercise any other rights). However, we may charge a reasonable fee if Your request is unfounded, repetitive, or excessive or refuse to comply with Your request in these circumstances. If You wish to exercise any of the rights set out above, please email us at: privacy@explorads.media.

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 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 for further information concerning Your request to speed up our response. We will 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 several requests.

What Are the Lawful Grounds for Processing Your data?

Our collecting and processing is necessary for the performance of a contract and our data processing agreements and/or addendums (Art 6 (1)(b)), including performance of our Services and operating our Platrform. In addition, ExplorAds processes personal data relying on Your consent (Art 6 (1)(a)). We may also rely (in exceptional circumstances) on legal obligations (Art 6 (1)(c)) or legitimate interest (Art 6 (1)(f)).

Data Retention

• We will only retain Your Personal Data as long as reasonably required to provide You with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes).
• If You are using the Platform as an advertiser or publisher, we will maintain Your registration information for our records unless and until You ask us to delete this information, or otherwise update said information.
• Data Related to Advertisements – We may retain other Personal Data within our databases, related to Your connection, advertisements served or other related information that we process on behalf of our Clients for the duration of the Services unless otherwise required specific legal obligations, dispute settlements or contract enforcement. After this period, The Company and its Vendors may maintain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, settle disputes and enforce contracts.
• If You withdraw Your consent to us processing Your Personal Data, we will erase Your Personal Datafrom our systems, unless the data is required for the Company to establish, exercise or defend against legal claims or it is necessary for the performance of the requested Services.

How do we protect Your information?

We use appropriate technical and organizational measures to protect Personal Dataagainst accidental or unlawful destruction or accidental loss, alteration unauthorized disclosure or access, in accordance with applicable law.

In the course of provision of Your Personal Data to us, Your Personal Datais likely to be transferred over the internet and/or stored on a cloud-based server. Although we make every effort to protect the Personal Data which You provide to us, the transmission of the Data over the internet and storage in a cloud-based server is not completely secure. As the communications with the Services is done by means of the internet, and as an online Platform, we cannot guarantee that the use of the Platform and Services or the interaction therewith will be 100% free viruses, worms, Trojans, and all other malware which are otherwise out of our reasonable control.

As such, You acknowledge and accept that we cannot guarantee the security of Your Personal Data transmitted to or automatically created by the Services we offer and that any such transmission is at Your own risk. We will not be liable for any damage caused by such unauthorized access or use, as long as we adhere to acceptable information procedures and measures.

Please note that You are responsible for the use of personally identifiable information and Your device. For example: in order to protect Your Personal Data from data incidents such online fraud (“phishing“), as do not provide identifying information to others (e.g. by e-mail), make sure that the contact information You provide us (including Your phone number and e-mail address) is correct. You should take steps to protect against unauthorized access to Your device(s) by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping Your Platform log-in and password private, use anti-virus measures, and computer security means on Your end equipment from which You browse our Website. You should make sure to update software, downloads only from official sites, use encryption, avoid using public computers or public WIFI networks, do not share sensitive information on social networks.

If You are concerned that Personal Data that You provided to us about You has reached unauthorized third parties, please contact us immediately at: privacy@explorads.media.

Data Breach

While we cannot guarantee misuse of data and or unauthorized access will not occur; we make good faith efforts to prevent such occurrences. We do not warrant or represent that Your account or any of Your information will be protected against, any misuse, by third parties.

In the case of a breach which we determine may have involved Your Personal Data, there will be timely efforts to contact You and also alerts to the relevant local authorities, to the extent required.

Do we disclose any information to third parties?

We may share Your information in the following circumstances:

• Third-Parties Service providers: we share Personal Data with our trusted service providers and sub-contractors including white-label market place platforms, technical, IT, hosting (including cloud base computing services), logistical or administrative services providers and, accountants, consults, insurers, and Client care service providers, as well as other outsourcing services required to provide our Services and operate our Website and certain functionalities, for the purposes stated in this Policy or upon Your request.
• Official Authorities. We may need to disclose Personal Data in response to lawful requests by public authorities or law enforcement officials, law enforcement requirements.
• Legal requirements: to the extent required or authorized by law, if we think it is necessary to comply with the law or if we need to do so to protect or defend our legal rights, or the rights of others (including to investigate and protect our users from fraudulent or unlawful use of the Website or the Platform), we will share Your Personal Data with third parties requiring information for legal reasons or third party investigators, authorities, regulators or law enforcement bodies.
• Your Personal Data will be shared with any of our affiliates where we consider that it is in our legitimate interests to do so for internal administrative purposes (for example, corporate strategy, and compliance, auditing and monitoring, research and development and quality assurance) including with our subsidiaries, affiliated and parent companies pursuant to the legitimate interest for the provision of the Site to You but their use of such information must comply with this Policy.
• Analytics providers that assist us in the improvement and optimization of the Website, the Platform and process Personal Data in the context of provision of analytical services to us.
• To prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service or any other agreement related to the Platform, or as otherwise required by law.To conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).
• Personal Data may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.

Direct Marketing

If You provide us with Your contact details through the Website where we indicate that such details will be used for the purpose of sending You different offers with respect to the Services, You hereby agree that we may use such contact details, in order to contact You, inform You regarding our products and Services which may interest You, and send You other marketing material, including news and updates by transmission to the e-mail address or phone number You have provided. You may withdraw Your consent at any time by sending us a written notice via email to the following address: privacy@explorads.media.

International Transfers 

If You are a resident of the EEA, It is possible, occasionally, that Your data will be transferred outside the EEA, to third parties service providers (such as IT, Host and marketing). we are subject to the provisions of the GDPR that protect Your Personal Data.

• When transferring Personal Data outside the EEA, we will usually:
  • In accordance with Article 46.2 of the General Data Protection Regulation (GDPR), include the standard contractual clauses approved by the European Commission Implementing Decision (EU) 2021/915 given on 4 June 2021 (hereinafter: “SCC” and/or “Standard Contractual Clauses”) for transferring Personal Data outside the EEA into our contracts with those third parties; or
  • In accordance with Article 45 of the GDPR, ensure that the country in which Your Personal Data will be handled (such as the State of Israel, where our Company is based) has been deemed “adequate” by the European Commission.

We will take means to ensure that certain safeguards are in place to provide a similar degree of security for Your personal data.  If no safeguards are available, we may request Your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time by sending us a written notice via email to the following address: privacy@explorads.media. 

Notice to California Residents

This section applies to California residents and outlines Your rights and choices with respect to ExplorAds processing of Your data under the CPRA.

ExplorAds is not in the business of selling data – We do not sell personal data for business or commercial purposes.

Consumer Rights:

In addition to other rights described under this Privacy Policy in relation to the Services, California consumers (users from the State of California) have the below rights under the CPRA:

• Right to know about the Personal Data is collected, shared, or sold including the categories of Personal Data, the categories of sources from which the Personal Datais collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom the business discloses Personal Data, and the specific pieces of Personal Datathe business has collected about the consumer. You may request that we disclose the categories of personal we collected, shared, sold, or disclosed in the past 12 months.
• Right to request the deletion of Personal Data: You may request the deletion of Personal Dataat any time. This can be done via Your account within the Applications. This right does not include any information we are required by applicable law to retain (for example, transaction data).
• Right to correct inaccurate data: You may request ExplorAds to rectify inaccurate Personal Datathat we maintain about You.
• Right to opt-out of the sale of Personal Data: ExplorAds is not in the business of selling, renting, or disclosing Personal Datato third parties for their direct marketing goals. We will only disclose Personal Data to third party marketers upon Your request.
• Right to Non-Discrimination: ExplorAds shall not discriminate against You when You decide to exercise any of the rights above.

Exercising Your Rights:

To exercise any of the CPRA rights above, don’t hesitate to contact us by emailing us at: privacy@explorads.media. We will fulfill Your request within 45 days of receiving Your request. We will verify Your request using Your email address. If You’ve created an account with us, we will also verify Your request using the information associated with Your account, including billing information. 

Note that we cannot respond to Your request if we cannot verify Your identity and confirm the Personal Datas related to You. Making a verifiable consumer request does not require You to create an account with us. If You wish to use an authorized agent to submit a request to opt-out on Your behalf, You must provide the authorized agent with written permission signed by You, the consumer. We may deny a request from an authorized agent if the agent cannot provide to us Your signed authorization demonstrating that they have been authorized to act on Your behalf.

A Children’s’ Online Privacy Protection Act Compliance (COPPA) Notice

The Platform and Services are intended for general audiences and are not directed to children under the age of 13. We do not knowingly collect Personal Data from children under 13. If You become aware that a child has provided us with Personal Data without parental consent, please contact us here: privacy@explorads.media.

If we become aware that a child under 13 has provided us with Personal Data without parental consent, we take steps to remove such information and terminate any account linked to such underage minor.

Cookies

We and third parties with whom we partner, may use cookies, web beacons, tags, scripts, advertising identifiers (“Cookies”) in connection with Your use of the Platform, third party websites, and mobile applications. Cookies may have unique identifiers, and reside, among other places, on Your computer or mobile device, in emails we send to You, and on our web pages. Cookies may transmit information about You and Your use of the Platform, such as Your browser type, search preferences, IP address, data relating to advertisements that have been displayed to You or that You have clicked on, and the date and time of Your use. Cookies may be persistent or stored only during an individual session.

Necessary Cookies

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

We also use the following third-party providers and you may learn more about their privacy practices by reviewing their privacy policies:

• WordPress -https://wordpress.org/about/privacy/cookies/

You can set some Cookie preferences through Your device or browser settings, but doing so may affect the functionality of the service over the Platform. The method for disabling Cookies may vary by device and browser, but can usually be found in Your device or browser preferences or security settings. Please note that changing any of these settings does not prevent the display of certain advertisements to You.

Changes to the Privacy Policy

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. The most current version of our privacy policy shall govern how we collect, use and disclose information about You. By continuing to use our services after changes to the privacy policy become effective, You acknowledge any such revised privacy policy.

How to Contact Us

If You have any questions about this Privacy Policy, You may contact us by mail or email at the following address: privacy@explorads.media.