2018 elementr. - all rights reserved.

privacy policy

23 May 2018

elementr. GmbH (“elementr.”, the “Company”, “we”, “us” or “our”) is a mobile advertising platform, offering its clients solutions to promote mobile applications (the “Services”).

At elementr., we are committed to respect the privacy choices of our website visitors, clients and business partners (both “Partners”), and end-users concerned by our Services.

This Privacy Policy (the “Policy”) describes how we use and to whom we disclose personal data that is collected by us or provided by you when you visit our website located at www.elementr.media (the “Website”) or use our services (the «Services»).

You will also find below the important information about your rights in relation to your personal data, please read the policy carefully.

elementr. GmbH (“elementr.”, “us”, or “we”) acts as controller of your personal data. Company is registered in Berlin under registration number HRB 194846 B, address Brunnenstraße 145, 10115 Berlin, Germany, email privacy@elementr.media.

By accessing the Website or using our Services, you become subject to this Policy. Your acceptance of the terms of this Policy, in their entirety, shall be effective to your employees, if any.


1. PERSONAL INFORMATION WE MAY COLLECT DIRECTLY FROM YOU

If you install and use an app that has been advertised through our platform, we will collect limited amounts of personal information about you, including:

  • Device information such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser, applications using elementr. Connect and the version of such applications, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or internal device identifier.
  • Information about your online activity including which adverts you viewed or clicked on and whether you visited the advertiser’s website or purchased the product or service advertised.
  • Log information, including the app used or website visited, session start/stop time, time zone, language, and network connection type. The geolocation of your device (using GPS or other data), when location services have been enabled for the mobile app or website that uses our technology.

We use this information to provide and improve elementr.’s services, including for:

  • Serving ads: Allowing publishers to offer advertising inventory in their mobile apps, and advertisers to bid on and fill that inventory.
  • Ad reporting and conversions: Reporting to advertisers information about when and how users have been shown their ads, clicked on their ads, and reporting to publishers information about when and how ads were shown on their properties and were clicked on.
  • Frequency capping: Preventing users from seeing the same ad too many times.
  • Fraud detection and prevention: Identifying invalid clicks (or ad queries) and protecting elementr. customers from fraudulent behaviour.
  • GeoTargeting: Where permitted by the user’s device, allowing elementr. customers to serve ads based on a user’s location.
  • Providing and improving our services: Auditing, researching, and analysing data in order to maintain, protect, and improve our services and develop new services, and to ensure that our technologies function properly.

When you contact us

If you contact us by telephone, email, post or using any other function offered by our website, we may collect your name, contact details, employer details, location and any other information that you provide to us.

We will use this information to review, investigate and respond to your questions or comments as necessary. Please note that we may record telephone calls made to us.

When you register with us

If you register with us as a publisher or advertiser, we will collect your name, contact details, employer information (if relevant), payment information, tax registration number.

We will use this information to:

  • create and maintain your account with us;
  • carry out our obligations arising from any agreements entered into between you and us;
  • respond to your queries and support your needs efficiently;
  • notify you about changes to our service or our products;
  • comply with any legal obligations to which we are subject; and
  • protect and defend our rights and interests.

When you sign up to receive marketing emails from us

If you sign up to receive emails from us, we will collect your name, email address, employer details (if relevant) and location.

We will use this information to send you emails about services we think you may be interested in, updates about us and/or the website and to notify you of any changes to our services.


2. PERSONAL INFORMATION WE MAY COLLECT FROM THIRD PARTIES

elementr. technology

If you interact with a website or app that uses elementr. technology, we may receive limited amounts of personal information about you, including:

  • Information about your online activity including which adverts you viewed or clicked on and whether you visited the advertiser’s website or purchased the product or service advertised.
  • Device information such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser, and the version of such applications, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or mobile device identifier.
  • Log information, including the app or website visited, session start/stop time, time zone, language, and network connection type.

We use this information to provide and improve elementr.’s services, including for:

  • Serving ads: Allowing publishers to offer advertising inventory in their mobile apps, and advertisers to fill that inventory. We may also use information about you that advertisers give us to deliver tailored adverts to you.
  • Ad reporting and conversions: Reporting to advertisers information about when and how users have been exposed to their ads, clicked on their ads, and reporting to publishers information about when and how ads were shown on their properties and were clicked on.
  • Frequency capping: Preventing users from seeing the same ad too many times.
  • Fraud detection and prevention: Identifying invalid clicks (or ad queries) and protecting elementr. customers from fraudulent behaviour.
  • Providing and improving our services: Auditing, researching, and analysing data in order to maintain, protect, and improve our services and develop new services, and to ensure that our technologies function properly.

Third Party Service Providers

We also work closely with third party service providers including, for example, business partners, sub-contractors, advertising networks, analytics providers and search information providers (“Third Party Service Providers”).

We may receive information about you from Third Party Service Providers such as Affise, Google and OVH. We may share some of the information we collect from you with Third Party Service Providers (see “Disclosure of Your Information” below).


3. PERSONAL INFORMATION WE AUTOMATICALLY COLLECT

When you use our website, we may automatically collect information including:

  • Information about your visit, such as:
    • the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time);
    • page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
    • the third party website from which you linked directly to the website (if applicable; and
    • methods used to browse away from the page and any phone number used to call our customer service number.
  • Technical information, such as :
    • the internet protocol (IP) address of your device;
    • mobile device ID (see below);
    • your log in information
    • browser type and version;
    • location and time zone setting;
    • browser plug-in types and versions;
    • operating system and platform; and
    • cookies (see below); and

Cookies are small text files that are stored on your computer. Cookies allow us to analyse the way our website is being used by you. You may prevent your browser from saving Cookies by adjusting the corresponding settings in your browser software.  However, please be advised that in such case, you may not be able to use all functions on website and/or on third-party sites to their full extent.


4. OUR LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION

Our legitimate business interests

If we have collected your personal information directly from your device, or if it has been provided to us by a publisher or advertiser, our legal basis for using your personal information is that it is necessary for our legitimate interests in conducting our business and facilitating the serving of adverts.

If you are a publisher or advertiser, or an employee of a publisher or advertiser, and we have collected your information in the course of our commercial relationship or in order to market to you, our legal basis for processing your personal information is that it is necessary for our legitimate interest in performing the contract between us and the business you are associated with.

Consent

If you have downloaded an app via elementr. technology, our legal basis for the installation and operation, including the collection of information from your device, will be your consent. App publishers collect this consent on our behalf.


5. DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any member of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, from time to time (our “group”).

We may share your information with selected third parties including:

  • Advertisers and advertising networks, to enable them to decide whether to bid for advertising space, whether to serve an advertisement and which advert is best for a particular device.
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them and/or you such as Affise.
  • Analytics and search engine providers including Google and OVH that assist us in the improvement of the website.
  • Third party service providers, to help us operate our business, the website or administer activities on our behalf, such as sending out newsletters or surveys.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
  • If we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect our rights, property, or safety, or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

We do not sell, trade, or rent your personal information to others.


6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

The personal information that we collect from you may be transmitted to third parties located in countries outside of the European Economic Area (“EEA”).

If you would like more information about how your personal information is transferred, and the safeguards applied, please contact us at privacy@elementr.media.


7. RETENTION OF YOUR PERSONAL INFORMATION

The period for which we will retain your personal information will vary depending on the purposes it was collected for, as well as the requirements of any applicable law or regulation.

For example, if you engage our services, we will store your personal information and details about your order for as long as is necessary to comply with applicable tax legislation, and for the period for which you or we could bring legal proceedings in relation to the services.


8. YOUR RIGHTS

You may have certain rights in relation to the personal information we collect about you. These may include the right to request access to the data we hold about you, or to obtain a copy of the personal information in machine readable format, to request that it is erased or that any inaccurate personal information is rectified. You may also have the right to ask us to restrict how we process your personal information or to withdraw your consent to how we process your personal information. Please contact privacy@elementr.media if you would like to make a request.

You also have the right to complain about the use of your personal data to the Supervisory Authority, which in Berlin, Germany is the Berlin Data Protection Authority; An der Urania 4 – 10, 10787 Berlin (www.datenschutz-berlin.de).


9. THIRD PARTY WEBSITES

The website may, from time to time, contain links to and from the websites of our partners, affiliates, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content on these websites and We are not responsible for the practices employed by them. If you follow a link to any of these websites, please note that these websites have their own privacy and customer support policies and we do not accept any responsibility or liability for these policies. Please carefully check these policies before you submit any personal information to these websites.


10. CHANGES TO OUR POLICY

This policy will be reviewed from time to time to take account of changes to our operations and practices. If we make changes, we will notify you by revising the date at the top of this policy, and if the changes are significant, we may provide you with additional notice, such as adding a statement to the homepage of the website or sending you an email with the update. Any personal information held will be governed by our most current policy.


11. CONTACT US

If you have any questions or requests regarding this privacy policy, the practices of the website or your dealings with the website, please contact privacy@elementr.media.

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