Privacy Policy

Last updated: 05.09.2022

ScreenCore is an advertising technology company that provides a variety of online advertising-related services. We are concerned about privacy issues and want You to be familiar with how we collect, use, and share information and how You can exercise the privacy rights available to You. This Privacy Policy (“Policy”) covers the information that We may process about end users through our services and about individuals who visit, use, or interact with the Website.

Who we are

Use of the terms "We" and "Us" in this Privacy Policy means ScreenCore Sp. z o.o., a limited company duly registered under the laws of Poland. We are a software development company that is focused on providing various services in a digital advertising market. We create and operate various digital technology platforms and render related services that connect buyers with sellers of advertising inventory.

Our Privacy Policies and GDPR compliance

These privacy policies disclose the order in which we ensure Your personal data protection, including the policies towards children. These policies are integral part of the user agreement that should be regarded by You with an equal attention.

ScreenCore processes the personal data of EU and non-EU based citizens alike, that’s why You need to read “The legal principles for EEA user rights processing” if You are EU citizen and Your personal data is subject to GDPR protection.

Our Privacy Principles

Your privacy and security are of the utmost importance to us. We will always follow these principles:

• Lawfulness, transparency and fairness;
• Purpose Limitation;
• Data Minimization;
• Accuracy;
• Storage limitation;
• Confidentiality and integrity.

What Information we collect and process

ScreenCore does not seek any personal information by illegal means. We collect only necessary information from You and other individuals who use the Website (Demand Partners and/or Supply Partners) by means of online order forms, registration pages and/or other similar means.

We collect information from and about the users of the Website:

• Directly from You when You provide it to us through the Website; and
• Automatically when You use the Website (some information – such as IP address and/or browser and device characteristics)

1. Information You may provide to us throw the Website

When You are filling out forms via the Website, We may ask You to provide information:

a) by which You may be personally identified, such as name, company name, email address, or any other personal or personally identifiable information under applicable law, and/or

b) that is about You but individually does not identify You.

This information may include:

• Information that You provide by filling in “Contact Us” form on the Website in order to use or access the Website/Services;
• Records and copies of Your correspondence (including email addresses), if You contact Us;
• Your responses to surveys that We may ask You to complete for research purposes.

2. Information Collected Automatically

While You use the Website, We may collect certain information that can be used to contact or identify You which also includes: IP address, cookies, usage data. This information is necessary to manage the Website, communicate with You about the Website, and for other purposes set out in this Privacy Policy.

You voluntarily consent to the collection, use and disclosure of such information by providing these information to us and by continuing to use the Website. Without limiting the aforesaid, if appropriate, You may be asked to provide Your consent when We collect, use, or disclose Your personal information in particular circumstances.

Cookies

The Company uses Cookies to associate certain Internet-related information about You and other individuals who use the website (Demand Partners and Supply Partners) with information about You in our database.

A cookie is a small amount of data stored on the hard drive of Your computer that allows us to identify You with Your corresponding data that resides in our database. Cookies do not reveal personal information. The only personal information a cookie can contain is information You supply Yourself such as email address, purchases and preferences. Cookies cannot read data from Your hard drive. If You want to delete cookies from Your computer, please go to Your browser settings and doit manually.

Log and Credit Card Information

When You log in to access Your account, our servers may automatically record and archive certain information that web-browsers send whenever visiting the website. These server logs may include information vital to validating Your authorization to access the account. Information, such as a web-request, Internet Protocol (the "IP") address, browser type, browser language, referring pages, exit-pages and visited URLs, platform type, click counts, pages viewed and in what order, time-spent, date and time of the request, and other important data is necessary to validate and authorize Your entry and activity on the website.

Credit Card Information includes credit card numbers and related information, such as the expiration date of the card, etc. We do not collect Your Credit Card information on the Website.

Use of Information

The Company will only use information provided by You and other individuals who use the Website (Demand Partners and Supply Partners) for purposes that You have provided it for, including those to operate, provide, improve, and maintain our website and services; to respond to Your inquiries and provide other customer services; as well as for other administrative and internal business purposes.

For example, we use the provided information for the following purposes:

Providing Our Services: Generally, we use the information we collect about end users to provide our products and services;

Ad Reporting and Conversions: To provide information and reports to Demand Partners about when and how end users have been exposed to their ads, clicked on their ads and/or visited their digital properties;

Frequency Capping: To prevent end users from seeing the same ad too many times;

Performance Analytics: To analyze ad performance, such as tracking views of ads, as well as click-through rates to websites or app stores and/or installs of apps that have been advertised;

Fraud Detection and Prevention and Security: To identify invalid ad impressions, clicks, installs, or ad queries, protect us and our Supply Partners from fraudulent behavior, and protect the security of our services;

Providing, Managing and Improving our Services: to display information more effectively, as well as auditing, researching, and analyzing information to provide, protect, manage, and improve our services, develop new services, and ensure that our technologies function properly;

Service Usage and Support: to help diagnose server problems, and administer the services;

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside an end user’s country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside an end user’s country of residence; (d) to enforce Our terms of service; (e) to protect Our operations or those of any of Our affiliates; (f) to protect Our rights, privacy, safety or property, and/or that of our affiliates, end users, or others; and (g) to allow us to establish or exercise our legal rights or defend against legal claims.

General Data Protection Regulation

General Data Protection Regulation (EU) 2016/679 (GDPR) is a European Union law governing privacy and data protection for all residents of the EU. The provisions of GDPR can be also applied to how data is processed and verified outside the European Union.

GDPR is intended to empower the citizens of the European Union to control their personal information. In accordance with the applicable laws, users are authorized to access and modify their own data held by the companies, which includes data collection, ad tracking, surveys, cookies, location data, and every other bit of a user’s “digital footprint”. Users are also entitled to transmit their personal details to other organizations. The GDPR also enforces companies to determine their in-house data security policies.

We maintain our commitment to protect the privacy of our users and abide by the legislation of all regions we operate in, including compliance with the GDPR.

Taking into account the above, personal data (if any) of our users is processed under the “purposes of legitimate interests” as outlined in GDPR Article 6(1)(f). Such an approach also helps us to fight against fraud and reimburse our contractors and agents. In accordance with the GDPR requirements, we will strive to, at any time, (i) streamline the data handling controls, (ii) specify our relationships with data partners, and (iii) provide the data subjects with an understanding and direct management of the way their personal information is used.

Personal Information: Personal information will be pseudonymized and encrypted to ensure the user privacy. The collected information will be handled for standard cases of use described in this Privacy Policy.

We will, to the best of our ability, make sure that our sub-processors operate in full accordance with GDPR requirements before starting cooperation with them and require such sub-processors to comply with this Privacy Policy and maintain appropriate security to protect user information from unauthorized access or processing, unless we have no ability to do so (for example, where we are sharing information with regulatory authorities or courts). Nevertheless, we cannot be held responsible or liable for the use of any information that a sub-processor may execute, or that is gathered by sub-processors. Whenever applicable, users should acquaint themselves with Privacy Policies of any of the involved sub-processors’ websites.

Data Retention: We will retain the gathered data for the period of the cooperation, but in no case longer than the maximum allowed by the existing legislation, unless You choose to withdraw it Yourself.

Residents of the European Economic Area Rights

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. ScreenCore strives to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

The General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. You (data subject) may send official requests to us regarding Your personal data via email to the following address: dpo@screencore.com

At any time, You have the right:

• Right of access: the right to be informed of, and request access to, the personal data we process about you;
• Right to rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete
• Right to erasure: the right to request that we delete your personal data;
• Right to restrict: the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to object: the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
• Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to automated decision-making: the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. Your request will be executed no later than 30 (thirty) days from the initial request receipt but we will do everything possible to process it within the first 48 working hours.

Should a data breach related to Your personal information occur, we will notify a relevant supervisory authority within 72 hours thereof.

California Residents Rights

According to the California Consumer Privacy Act (“CCPA”) then amended by The California Privacy Rights Act (CPRA) the California residents have the following rights listed in this clause:

You have the right to request deletion of your personal information that we have collected, subject to certain exemptions, and to have such personal information deleted, except where necessary for certain exempt purposes.

You have the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.

You have the right to request a description of the categories of personal information about you that we have collected, used, disclosed or sold in the prior 12 months. Specifically, you may request a description of the:

• categories of personal information we have collected;
• categories of sources from whom we have collected personal information;
• business and/or commercial purposes for collecting or selling your personal information;
• categories of third parties with whom we have disclosed or shared your personal information;
• categories of personal information that we have disclosed or shared with a third party for a business purpose; and
• categories of third parties to whom we have sold personal information and the specific categories of personal information sold to each category of third party.

You have the right to opt out of the sale of your personal information.

You have the right not to be discriminated against because you exercise your rights under the CCPA

To submit an opt-out request, please contact us at dpo@screencore.comand/or submit the required verifying information, by contacting us here.

Sale of Personal Information

We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a “sale” under the CCPA. We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction. To exercise these rights, You can contact us by email at dpo@screencore.com. Whenever You have any question regarding the process of how we handle Your data, don’t hesitate to inform Us.

Brazil Residents Rights

ScreenCore comply with the principles and requirements of data processing under the Lei Geral de Proteção de Dados Pessoais (LGPD), including, but not limited to, age-gating requirements. All the data received by using our services is anonymized and therefore falls outside the scope of LGPD.

You have the following rights under the LGPD:

• Confirmation: confirmation of the existence of processing;
• Access: access to the data;
• Rectification: correction of incomplete, inaccurate or outdated data; anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of LGPD;
• Data portability: portability of the data to other service providers or suppliers of product, at the express request;
• Anonymization: anonymization, blocking or elimination of the personal data processed with the consent of the data subjects, except in the events set forth in article 16 of LGPD;
• Deletion: You have the right to have their personal data deleted if the processing of that data was based on consent;
• Information: You have the right to be informed about sub-processors and other third parties that access or process their personal data. You also have the right to be informed about Your consent choices and the consequences of refusing consent;
• Revocation: revocation of the consent, pursuant to the provisions of paragraph 5 of article 8 of LGPD;
• Bring complaint:
• opposing the processing of personal data where there is non-compliance with the provisions of LGPD;
• Request review: You have the right to request the review of decisions made solely on the basis of automated processing of personal data which affect Your interests. This includes decisions used to define Your personal, professional, consumer and credit profile, or the aspects of Your personality.

If you would like to exercise any of these rights, please contact us via: dpo@screencore.com

China Residents Data Privacy Rights

ScreenCore comply with all the principles and requirements of data processing under the Personal Information Protection Law (the “PIPL”), including, among others: accuracy, accountability and security, purpose limitation, collection limitation, openness and transparency, lawfulness and necessity.

You have the following rights under the PIPL:

• You have the right to know, decide, refuse, and limit the handling of their personal information by others unless laws or regulations stipulate otherwise;
• You have the right to access and copy your personal information in a timely manner, except when the laws and regulations require confidentiality;
• You have the right to correct or complete inaccurate personal information in a timely manner;
• You have the right to request Us to explain Our personal information handling rules;
• You have the right to deletion of Your personal information if (i) the agreed retention period has expired, or the handling purpose has been achieved; (ii) We as a personal information handler cease the provision of Our services; (iii) You rescind consent where the processing of personal information was based on Your consent; (iv) the information is handled in violation of laws, regulations or agreements;
• You have the right to request Us to transfer Your personal information to another personal information handler.

If you would like to exercise any of these rights, please contact us via: dpo@screencore.com

Data Protection Rights of The Residents of Virginia and Colorado

ScreenCore expresses its willingness to comply with any and all the principles and requirements of data processing under Virginia Consumer Data Protection Act (VCDPA) effective January 1st, 2023 and under Colorado’s Consumer Data Protection Act (CPA) that will be effective on July 1, 2023

If You have any questions in regard to Your rights under the aforementioned legislation, please don’t hesitate to contact us via: dpo@screencore.com

The use of email addresses

Your email address will only be used for the purposes of contacting You in order to fulfill these services offered by Company. This may include notifications on offer changes, Your campaign updates, Company newsletters, notes about Your results, etc. Email addresses will never be provided to any third party, without a written approval, or an electronic consent from You. Users can opt out from Company newsletters and from other email related activities by adjusting settings of their accounts, by unsubscribing from the newsletters themselves using an opt-out link, or by providing the company with a written notice (email is sufficient).

Dissemination of Information

Your Personal Information will not be shared unless we have first given You notice that we might share Your data, and You have authorized us to do so. The Company receives information from You and other individuals who use the website, and have the right to use this data (sometimes, in connection with Non-Personal data), but is generally prohibited from sharing this information with other companies or people.

Your Non-Personal data will not be linked with Your Personal Information or be shared, unless we have given You notice as described above and You have given us authorization to do so.

Security

Security of Your information (Personal data and Non-Personal data) is our utmost priority. authorized employees have access to the information You provide Us. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we process which included:

• using secure shell protocol (SSH);
• multi-factor authentication;
• access control (physical and technical);
• link encryption;

Our data is only stored in centers that provide the highest quality security for Your information. Only authorized employees have access to the information You provide Us.

Contact Us

If you have any questions about this Policy or ScreenCore’s privacy practices, please contact Us by email at either dpo@screencore.com or legal@screencore.com, or by mail using the details provided below.

Please note that email communications are not always secure, so please do not include sensitive information in your emails to us.

Registered address for the mail correspondence:
SCREENCORE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ,

Chodakowska Str., nr 53/57, lok. 22A, Warsaw, kod 03-816, poczta Warsaw, Poland