IVT COMMUNICATIONS FZE LLC here referred to as «afina data monetization platform», ”Company”, “we”, etc., commits to the compliance with data protection laws and the following Privacy Policy states the practices that are used by us to collect personal data and the services we provide to Advertisers and Publishers (“You”, “Your” etc.), and shares practices for www.afinadmp.com (the/our “Website”, “the Platform”).
By visiting this website and requesting information, products, or services, you agree to be bound by the terms and conditions of this privacy policy. if you do not agree with the terms of this privacy policy, please do not provide any information, or use any of the services or products offered or provided on any of the websites referred to in this privacy policy.
PLEASE NOTE: This privacy policy changes from time to time and changes are effective upon posting. Please check back frequently for updates as it is your sole responsibility to be aware of changes. We do not provide notices of changes in any manner other than by posting the changes at this web site.
This policy describes the information collection, use, and dissemination practices of afina data monetization platform, and applies to afina data monetization platform collection use, storage and disclosure of information on its:
(a) websites, including all its divisions, subsidiaries and related companies (collectively, the "Websites"),
(b) on various Third Party websites
THE INFORMATION COLLECTION, USE AND DISSEMINATION PRACTICES OF afina data monetization platform
WHAT IS PERSONAL DATA?
Afina data monetization platform collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by Third Parties (collectively, a "Survey"). As used herein, "online" means using the Internet, including the Websites, and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.
In this Privacy Policy, “personal data” means any information relating to you as an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
For the avoidance of doubt, personal data does not include data from which you cannot be identified (which is referred to simply as data, non-personal data, anonymous data, or de- identified data).
In this Privacy Policy, “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Afina data monetization platform may also collect information concerning an individual from another source and uses that information in combination with information provided from this website. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to afina data monetization platform or Third Party, but an individual may receive incentives from afina data monetization platform or a Third Party in exchange for providing Survey Information to afina data monetization platform.
Afina data monetization platform encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. Afina data monetization platform will never knowingly collect any personal information about children under the age of 18. MINORS UNDER THE AGE OF 18 SHOULD NOT PROVIDE ANY PERSONAL INFORMATION, INCLUDING THEIR EMAIL ADDRESS, TO afina data monetization platform. If afina data monetization platform obtains actual knowledge that it has collected personal information about a child under the age of 18, that information will be immediately deleted from our active database. Because it does not collect such information, afina data monetization platform has no such information to use or to disclose to Third Parties. afina data monetization platform has designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA").
HOW DO WE COLLECT PERSONAL DATA AND FOR WHAT PURPOSES
Afina data monetization platform collects the personal data on the moment the you sign-up in the Website, with yours consent. Subsequently, you may enter into an agreement or contract with, afina data monetization platform and where this is the case, personal data will be processed only as is necessary for the performance of that agreement or contract or in order to take steps at your request prior to entering into that contract or agreement. By submitting your information to us, you agree to the processing set out in this Privacy Policy. After that, your personal data is stored while your partnership with afina data monetization platform is ongoing and once said the relationship is terminated for whatever cause, unless you oppose to it. Once the relationship is terminated, your personal data will be processed solely to the effects of demonstrating compliance with the legal obligations of the Company or only as is necessary for the purposes of any legitimate interests pursued by afina data monetization platform or by a third party (and in the latter case, only to such extent as those legitimate interests are not overridden by your interests or fundamental rights and freedoms). As a data subject, you have rights under applicable legislation to access, change/rectify, request deletion or restriction, object of processing, or requesting to receive or for us to transfer (port) your personal data free of costs at any time, according to the law in force. Further information on these rights is included within this Privacy Policy.
Afina data monetization platform collects and processes personal data needed for the provision of services. We may collect and process the following data about you, depending on your relationship with afina data monetization platform:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details (where applicable).
- 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 Website. This data also includes information about how you use our website, services, and navigate through the website, and may not necessarily comprise personal data. It may for example include information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our 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), methods used to browse away from the page, any phone number used to call, and other information.
-Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.If you fail to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, and we may not be able to provide our services. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.afina data monetization platform websites contain links to external websites. You will be taken to external websites if you click on these links. Your information may be passed from afina data monetization platform database to the external website, and/or external database, for your convenience (e.g. your information may be used to pre-fill a form at a destination website). afina data monetization platform is not responsible for the privacy practices or content of any external website owner. We encourage you to review the privacy policy of any website they visit.
We and other organizations may also access and use your personal data to conduct ‘know your client’ (“KYC”) checks, credit checks and checks to prevent fraud, money laundering and terrorist financing (“AML/CFT”). If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to the relevant authorities including credit reference agencies and fraud prevention agencies. We will also record this. Law enforcement agencies may access and use this information. We, and other organizations that may access and use information recorded by such agencies, may do so from other countries.
We may process any of your personal data where it is necessary to establish, exercise, or defend legal claims. the legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.Further, we may process your personal data where such processing is necessary in order for us to comply with a legal obligation to which we are subject.
Contact data can be used for communication purposes, including but not limited to email messaging (system email, marketing email, etc.)
CONFIDENTIALITY AND SECURITY
Afina data monetization platform commits to taking all the necessary measures to prevent and secure the data that’s collected and treated, preventing them from being damaged, destroyed or even stolen. However, we don’t control every risk associated with internet usage, so there’re always risks associated with the usage of internet and data sharing online.No data transmission over the Internet or website can be guaranteed to be secure from intrusion; any transmission is at your own risk. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
All information you provide to us is stored on our or our subcontractors’ secure servers in various sites in the world and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
THIRD PARTIES ACCESS
Your data may be transferred to third parties for compliance with legal obligations to which the Company is subject based on its activity, or as may be required in order to provide the services that those third parties were hired for. Advertising agencies, advertising networks, and other companies (together, "Advertisers") with whom afina data monetization platform has subscribed will need to enter into confidentiality and data processing agreements that are necessary and mandatory under any applicable privacy legislation. We may permit selected third parties such as business partners, suppliers, service providers, agents and contractors who will be subject to obligations to process such information in compliance with the same safeguards that we deploy, to use your personal information.
We may also use third party applications and software for the purposes of creation and maintenance of mailing lists, webform collection, and transmission of social media links. We are not responsible for the privacy practices and policies of such third party service providers and you are strongly encouraged to review such policies in order to ensure you agree to the processing of your personal data by third parties in the manner described therein. We will however, to such extent as reasonably possible, ensure that third parties we use keep your information secure and agree not to use it for their own direct marketing purposes.The Websites and email messages sometimes contain hypertext links to the websites of Third Parties. afina data monetization platform is not responsible for the privacy practices or the content of such other websites.
In addition, we may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.Finally, as described in the previous section, relevant authorities including credit reference agencies and fraud prevention agencies may be given access to your personal data in connection with our relevant KYC and AML/CFT obligations.
YOUR RIGHTS AS A DATA SUBJECT
Right to information
You have a right to be informed about the processing of your personal data (and if you did not give it to us, information as to the source) and this Privacy Policy intends to provide such information. Of course, if you have any further questions you can contact us on the above details.
Right of access
You have a right to obtain confirmation from us as to whether or not your personal data are being processed and, where this is the case, a right of access to your personal data. We have an obligation to provide additional information when complying with an access request, and we have endeavored to capture this information within this Privacy Policy. We are happy to provide you with details of the personal data that we process about you. To protect our customers' personal information, we follow strict storage and disclosure procedures, which means that we will require proof of identity from you prior to disclosing such information. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Right to rectification
You have the right to have any inaccurate personal data rectified and to have any incomplete personal information about you completed.
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. If we do hold personal data and you believe it is incorrect, you may submit a request to us to correct any alleged mistakes.We shall communicate any rectification of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to be forgotten
You have the general right to request the erasure of your personal information in the following circumstances:
- the personal information is no longer necessary for the purpose for which it was collected;
- you withdraw your consent to consent based processing and no other legal justification for processing applies;
- you object to processing for direct marketing purposes;
- we unlawfully processed your personal information; and/or erasure is required to comply with a legal obligation that applies to us.
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
- Exercising the right of freedom of expression and information;
- Complying with a legal obligation under UAE or other applicable law;
- The performance of a task carried out in the public interest;
- Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
- The establishment, exercise, or defense of legal claims.
We shall communicate any erasure of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to restrict processing
Instead of requesting erasure, you also have the right to restrict processing of your personal information where:
- you contest the accuracy of the personal information;
- processing is unlawful, but you do not want us to erase it;
- we no longer need to process your personal information but you need us to retain your information as you need it for the establishment, exercise, or defense of 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.
We shall communicate any restriction of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort, and shall inform you about such recipients if you request it.
Right to object to processing
You also have the right to object to processing of your personal information under certain circumstances, such as:
- where the processing is based on your consent and you withdraw that consent;
- 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; or
- where we are processing your personal data for direct marketing purposes
Exercise of this right may impact the services we can provide and we will explain this to you if you decide to exercise it. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and this may allow us to continue to (wholly or partly) process your personal information.
Right to data portability
With respect to automated information which you initially provided consent for us to use, or where the processing is necessary for the performance of a contract to which you are party (or in order to take steps at your request prior to entering into a contract), you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
Right to object
You have a right to object at any time to processing of personal data (including profiling) concerning you which is based on:
- the performance of a task carried out in the public interest or in the exercise of official authority vested in a controller;
- orthe legitimate interests pursued by a controller.We do not process personal data on grounds of public interest or exercise of official authority.
We do however rely on our legitimate interests as a lawful basis for processing personal data as outlined in this Privacy Policy. This applies, in particular, in the context of directly marketing to you.
We will only send you marketing information where you have agreed to opt-in to receive it. You have a choice about whether or not you wish to receive direct marketing information from us. We will not contact you for marketing purposes unless:
- you have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above); or
- you have otherwise given your prior consent.
We will only use your preferred communication channels to contact you, and on each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You can change your marketing preferences and/or opt-out at any time by contacting us on the above details.
Please note that any administrative or service-related communications (to offer our services, or notify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.
EU Data Subject Rights: Access, Rectification, Erasure, and Restriction
In operating our site, we process data as a processor (as such terms are defined in the GDPR).
As a processor, we are committed to fulfill data subjects’ (‘Users’) GDPR rights.As an EU resident, you have the right of access (Art 15 GDPR), the right to rectification (Art 16 GDPR), the right to erasure of your personal data (Art 17 GDPR), the right to restriction of processing of your personal data (Art 18 GDPR) as well as the right to data portability (Art 20 GDPR). Furthermore, you have the option to file a complaint against the processing of your personal data with the competent supervisory authority.
As an EU resident, you may:
1. contact us at any time at: sales@afinadmp.com and request to access the personal information that we keep on you. We may ask you to provide us certain credentials to verify your identity before granting access to or making any changes to your Personal Information;
2. send an e-mail to us to seek rectification, if you find that the data is not accurate, complete or updated;
3. send an e-mail to us to request erasure or restriction of Personal Information held about you by us. We will respond in a reasonable time. Please be advised that we may retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Therefore, may postpone or deny your request if your personal information is in current use;
4. if you have given your consent to the processing of your data, you can revoke the given consent at any time.
CONTACTING US
If you have questions or concerns regarding this statement, you should first contact us through email. You can address your general questions and comments by e-mail to sales@afinadmp.com
This website is owned and operated by IVT COMMUNICATIONS FZE LLC; a company incorporated in a legal entity established and operating in accordance with the laws of the UAE, located at the address: A-60-01-02-09 – Flamingo Villas, Ajman, Registred number: 3621.