Privacy Policy

Privacy Policy

Introduction

The integrity of individuals is an important factor for Clicktron.  Clicktron S.L. and Clicktron will herein after be referred to as “Clicktron”.  Clicktron’s advertisers, publishers, media agencies and other customers (hereafter the “Client/Clients”) that from time to time provide Clicktron with personal data, as well as web surfers whose digital data is processed by Clicktron as part of its provision of services to it’s Clients (hereafter the “User/Users”), must be able to trust that data is processed by Clicktron in accordance with applicable privacy laws and regulations.

This Privacy Policy was created in order for Clients and Users to better understand how information relating to them is processed by Clicktron. The Privacy Policy is not exhaustive, but contains certain fundamental privacy principles applied by Clicktron.

  • Part 1 of the Privacy Policy contains Clicktron’s general privacy principles with regard to its processing of personal data provided by Clients, Users or other individuals.
  • Part 2 of the Privacy Policy contains information regarding Clicktron’s processing of digital information about Users in relation to Clicktron’s Interest Based Advertising and possible Retargeting activities. It also contains requirements on publishers with whom we have contracted to serve Interest Based Advertising, Retargeting and other marketing services, to notify Users about Clicktron’s services on their websites.

This Privacy Policy was last revised on January 16, 2015. Clicktron may at any time and without notice change it, e.g. to keep it compliant with applicable laws. You should therefore read this Privacy Policy each time you intend to provide Clicktron with personal data.

Part 1 – General privacy principles

Personal data and controller of personal data

Personal data comprises all information that directly or indirectly can be referred to a natural person who is alive, e.g. name, postal address, e-mail address and phone number. A controller of personal data is the natural or legal person who processes personal data and who decides why and how such data shall be processed.

Clicktron is the controller of personal data provided by you through the website ‘www.clicktronmedia.com’. Clicktron is the Controller of personal data provided to us by you through sub-sites of www.clicktronmedia.com, that are published and maintained by Clicktron or its subsidiaries (all Clicktron websites hereafter referred to as the “Site”) unless otherwise indicated when such data is collected, or personal data that you are asked to provide us with in other situations if not otherwise is indicated.

Collection of personal data

Personal data for which Clicktron is controller may be provided by you to us e.g. in the following situations:

  • If you are a Client you may be required to provide us with personal and corporate information, such as name, address, email address and other account information, in order to be able to access and use our services;
  • As part of our sales efforts, we may collect and store data through online forms for contact purposes;
  • If you are a prospect Client, you may provide us with personal data through this Site when applying to join our network;
  • You may provide us with personal data when you send us inquiries relating to our services or in relation to this Privacy Policy;

Use of personal data

Clicktron is committed to protect any personal data you provide to us and to process your personal data in accordance with this Privacy Policy and applicable laws.

Personal data provided to Clicktron may be used for the following purposes:

  • Provide you requested products and services;
  • Manage Clicktron’s agreed obligations and rights towards you;
  • Process payments; administration;
  • Internal analysis to improve or more effectively tailor Clicktron’s Site, business or offerings generally;
  • Allow you access to agreed products and services;
  • Direct marketing;
  • Any other purpose you have consented to or which is allowed under applicable law.

Your personal data may also be processed for additional purposes stated on any relevant part of the Site or otherwise in connection with the provision to us of your personal data. Your personal data may be combined with other information collected from you or third parties for the above purposes.

Disclosure and transfer of personal data

Personal data may be transferred to other companies within Clicktron (and hence Clicktron S.L.). Clicktron may as a consequence of service agreements with third parties, also transfer personal data to such third parties who process personal data on behalf of Clicktron. Such service agreement shall contain obligations for third parties to process data only in accordance with Clicktron’s instructions and to take appropriate measures to secure that the processing of the personal data is secure.

For any of the purposes described herein, personal data may be transferred to Clicktron’s business partners within or outside the EU/EEA. Should any of the recipients reside in a country without adequate legal protection for personal data, Clicktron will make reasonable efforts to make the recipient adopt the principles described in this Privacy Policy.

Consent

Where it is required by law or where Clicktron otherwise deems it appropriate, Clicktron will seek consent from you before Clicktron processes your personal data. Such consent may e.g. be obtained by asking you to accept processing of your personal data in accordance with this Privacy Policy. If you do not agree to this Privacy Policy and/or other terms and conditions stated in connection with the collection, please do not provide personal data to Clicktron. Clicktron reserves the rights not to provide you certain products or services should you choose not to provide required personal data.

Withdrawal of consent

You are at all times entitled to withdraw your consent to process personal data that you have provided to Clicktron. In such case Clicktron will not process your personal data based on consent any more.

You are entitled to request that Clicktron shall not process your personal data for direct marketing purposes any longer by writing an email to info@clicktronmedia.com with subject line “withdrawal of consent” and with your contact details (first name, last name, company name, email address, etc.) clearly listed in the email.

Right to information and rectification of personal data

Clicktron will take reasonable measures to rectify, block or erase personal data that it is shown incorrect without undue delay. You should contact info@clicktronmedia.com if you would like us to correct personal data that we hold on you and which you consider incorrect.

You may request a copy of the personal data that Clicktron holds about you. You are entitled to such information free of charge upon simple request. This information will include information regarding what personal data Clicktron processes about you, where such information has been collected, for which purpose the information is being processed, and to whom, or to which categories of persons, the information is being disclosed.

Security

Clicktron is dedicated to maintain the security of personal data and preventing unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include that personal data may be accessed only by a limited number of persons within Clicktron.

Our employees are made aware of and must comply with Clicktron’s security standards. When we occasionally use third-party contractors to perform tasks that might otherwise be performed by our employees, these contractors are contractually bound to adhere to this Privacy Policy and they are subject to similar restrictions as our employees.

Cookies

This Site sends your browser a cookie – a small piece of data stored on your computer’s hard drive. The purpose of the cookie is to improve your reading of and your search possibilities on our Site. If you are a registered Client (e.g. a publisher), the cookie will also manage and control your login and session on those part of our Site that are only available to registered Clients.

If you do not want to accept that your computer receives and stores cookies, you can alter your security settings on your web browser (Internet Explorer, Netscape etc.). However, note that certain parts of our Site may only be used fully if your browser allows cookies. Thus, your reading experience of our Site may be affected negatively by removing and not allowing cookies.

Part 2 – Interest Based Advertising and Retargeting privacy principles

What is Interest Based Advertising and Retargeting?

Clicktron’s Interest Based Advertising and Retargeting services are cookie based. “Cookies” are small simple text files (not programs or spyware) stored on the hard drive of a web surfer’s computer. Based on the anonymous information stored in the User’s cookie, Clicktron is able provide more relevant advertising to the User on behalf of our Clients.

The fundamental integrity principle underlying all Clicktron’s processing of digital data relating to Users, is that such data shall be anonymous. Therefore, we do not store IP addresses on the cookie of a User, only a unique randomly generated ID that does not allow Clicktron to trace the User; we do not have, and will not initiate, any co-operation with Internet Service Providers in order to trace the identities of Users. The data stored on the cookie is limited to information collected at the User’s visits to websites belonging to Clicktron’s Advertising Network. A User’s cookie can only be viewed by Clicktron when the User visits a website that belongs to our Advertising Network. If the cookie is deleted by the User, all profile data is removed. In addition, note that you are always able to prevent cookies from any website from being installed on your computer by readjusting your browser settings. For more information about cookies and how to disable them, you should consult the help section of your browser.

Use of collected digital data

Clicktron will use the User data in order to better target advertisements on behalf of our Clients, to provide aggregated non-personal reporting to our Clients, and to improve our advertising systems and products. The data may be combined with other anonymous information collected from other sources so that we may better serve Users with offers that may be of interest to them.

Security

Clicktron is dedicated to maintain the security of all its data and to prevent unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include access restrictions, i.e. that data may be accessed only by a limited number of persons within Clicktron.

Our employees are made aware of and must comply with Clicktron’s security measures. When we occasionally use third-party contractors to perform tasks that might otherwise be performed by our employees, these contractors are contractually bound to adhere to this Privacy Policy and they are subject to similar restrictions as our employees.

Publisher notification

If you are a publisher, please note that you are obligated to notify visitors of your website about third parties who are serving advertisements on your website by way of use of cookies. As party to the publisher agreement with Clicktron, you agree to provide clear and unambiguous notice about this.

For avoidance of doubt, please note that the foregoing requirement of notification does not limit any of your obligations according to applicable law. You are yourself as a publisher responsible for providing relevant and accurate information required by law, including applicable privacy laws.

For general inquiries concerning this Privacy Policy or Clicktron’s processing of data, display and deleting of your profile, opt-in & opt-out management of data, etc. please send an e-mail to the following address: info@clicktronmedia.com.

Please provide relevant details in your e-mail in order for Clicktron to be able to process your request or inquiry.