ΠΟΛΙΤΙΚΗ ΑΠΟΡΡΗΤΟΥ ΤΗΣ ENGAGEYA
Last Updated: December 13, 2018

Engageya is an online content engagement widget, operated by Beaconspark Ltd. (we, us or Engageya). Engageya greatly values its end users privacy, so we have designed this Privacy Policy (Privacy Policy) to explain to you about our data collection and protection practices, when you access, use, interact or engage with our site (available at: www.engageya.com), widget and any respective content, our analytics tools, engines, technologies and/or services that we make available to different type of customers (respectively, the Site, Platform and jointly, the Services).

Please be aware that this Privacy Policy is an integral part of our Terms and Conditions (available at: www.engageya.com/terms), whether you are an end consumer who interacts with the Services or a business entity who engages with us and integrates the Services into your business and online properties.

If you do not agree to this Privacy Policy and to the data collection practices we describe here, unfortunately we will not be able to provide you with our Service. In some cases, however, if you are end user, you will be able to opt out from having our Services using your personal data, as described below under the choices and opt out section.

Please make sure you read this Privacy Policy carefully, understand it and consent to its terms. If you have any questions about our Privacy Policy, you are welcome to reach out to us: privacy@engageya.com, Esentepe Mahallesi, Talatpaşa Cd. No:5, 34394 Şişli/İstanbul, Turkey, +44-20-80895641

WE MAY MODIFY THIS PRIVACY POLICY

We may, from time to time, modify, add or delete provisions of this Privacy Policy. Your use of the Website or Services following the effective date of any such modification means your consent and acceptance to the modified Privacy Policy. In cases of material changes, we will make sure to provide you with a more prominent notice, for example, posting a note on the Website, Services or similar method.

This Privacy Policy includes:

  • Application of this Privacy Policy
  • If you are a Customer
    • Information we Collect About Customers
    • Our Use of Customer Information
    • Sharing Customer Information
    • Your Choices
  • If you are an End User
    • Information we Collect About End Users
    • How We Collect End User Information
    • How Do We Use User Information
    • Sharing or Disclosing User Information
    • Users Choices
    • Links to Third-Party Websites
    • Information Security
    • Data Retention
    • Cross-Border Data Transmission
    • Children’s Privacy
    • Comments and Questions

  • APPLICATION OF THIS PRIVACY POLICY
  • This Privacy Policy explains Engageya’s data collection practices that apply toward (i) our business’ Services consumers, whether they are publishers, advertisers or any other type of business partners (Customer/s) and (ii) the data practices relating to visitors of the Site and our Customer’s websites and/or products (End User/s); Customers and End Users will be jointly be referred to as Users. Lastly, the Privacy Policy refers to general provisions, which are applicable to both Customers and Users. Capitalized terms will have the meaning given in the Engageya Terms or here, in this Privacy Policy. When we use the term Personal Information we mean information that may be used, either alone or in combination with other information, to personally identify an individual (natural person), such as a first and last name, an email address, phone number, a home or other physical address, and other contact information. In some jurisdictions and given the specific use we make with the information, IP address that your Internet service provider allocates for your device, may also be considered as Personal Information (in the European Union for example). In which case, we will be treating the information as personal in all handling and safeguarding aspects, however, Engageya does not make any use of such information for identification or personalization purposes and we do not combine such data with another in attempt to identify you.

  • IF YOU ARE A CUSTOMER:
  • If you are a Customer of the Services, in addition to the User Information we collect, we may collect Personal Information that you are required to submit to us when you open an account with us, for purposes of engaging with us in a business relationship or to otherwise integrate our Services into your own sites, products, software and services. In which case, our data collection practices will be as follows:

    • INFORMATION WE COLLECT ABOUT CUSTOMERS
    • in addition to information we may collect about End Users, (as detailed below), if you are a Customer and you choose to open an account and sign up, you will be asked to submit certain Personally Identifiable Information, such as first and last name, email address of the entity on which behalf you are engaging with us, a password for accessing your account and information about your website that you wish to register with us. We will also collect other Information that Customers choose to provide to us, such as communications a Customer submits to us through our Services (collectively Customer Information).

    • OUR USE Of CUSTOMER INFORMATION
    • We use Customer information in order to (i) render our Services and contact Customers that express their will to communicate with us and/or engage with the Services; (ii) communicate with Customers and respond to any inquiry or any other form of communications from Customers; (iii) providing Customers with newsletters, promotions, updates, and other information Customer may find useful, including via email;

    • SHARING CUSTOMER INFORMATION
    • We may disclose or share Customer Information to a present or future (i) affiliate, parent companies and/or subsidiaries that help us with facilitating the Services or operating the Website; (ii) services providers, agents, contractors, vendors and any other individual or entity which requires access to Customer Information in order to perform their functions; (iii) other Customers, to the extent required to render the Services and consented by Customer.

    • YOUR CHOICES
    • As a Customer of us, you have certain rights concerning your Customer Information, including: edit, correct, verify, update or delete your Customer Information. If you wish to exercise any of those rights, you may do so by contacting us directly at: privacy@engageya.com. In addition, any email communication we send to you, will include an opt-out / unsubscribe option that you can directly exercise via the email communication. Please note that if you choose to unsubscribe from email communication, we may still hold your account information and Customer Information and may contact you for updates regarding your use of the Services or any other relevant account information.

  • If YOU ARE AN END USER:
  • If you are an End User of the Services, the following data privacy practices are relevant for you:

    • INFORMATION WE COLLECT ABOUT END USERS
    • When you visit the Site or access, interact or engage with the Services, we may collect some information about such use as dependence of the type of the Service (and respective technology) with which you interact. Such information generally includes the following: device information (such as type, operating system type, version and language), your user agent, that includes the browser type, version and language from which you access or use the Services, the domain or URL of the website you browse in which the Platform is integrated, and the Services are displayed or served. We may also collect the IP address of the device that accessed to the Services for purposes of bot or real End User validation and fraud detection, in which case such data is retained separately from other data items with no ability to correlate the IP address with other data (User Information). IP address may also be used to extract aggregated, non identifiable information, such as the country and region of the End Users and to facilitate demand bidding. User Information and Customer Information will be jointly referred to as Information.

    • HOW WE COLLECT END USER INFORMATION?
    • Like most online service, we also use Cookies (also known as web beacons), pixel tags and similar web technologies to collect User Information:

      • Cookies
      • A cookie is a small text file that is placed on the browser of the hard drive of your computer (or similar device) by websites that you visit. Most websites and online services use cookies. Cookies are typically used (together with web beacons) in order to make websites or web services function, or function more efficiently, as well as to provide information to the owners of the particular website or service. Cookies make your use of the Services easier to use and improve their functionality. Additionally, in some of the Platforms we operate, Cookies are essential for the proper functionality of that Platform and the Services that are available by it. Most browsers are automatically set to accept cookies, but you can usually modify your browser settings to disable cookies or to completely remove them. If you choose to disable cookies though, you will still be able to access the Website and use the Services, but some features and services may not properly function.

      • Web Beacons
      • We, or advertisers partners, may use standard Internet technology such as web beacons (or clear gifs), tracking pixels, and other similar technologies, to gather analytics, anonymous, aggregate, non-personally identifiable information about End Users that interact with the Services or the content that is available on top. Please be aware that some third party content, features, elements and services that are not necessarily provided by us (Third Party Content). Such Third Party Content may include graphics, animation, video, ads, offers, links, buttons or any their similar feature with which you may engage. Any interaction you make with such Third Party Feature is govern by their providers’ policies, terms and conditions, so we advise you to refer to their privacy policies to learn more about their data collection and protection practices.

      • Log Files
      • Technical information from your browser is automatically collected into a log file, when a you visit our Site or interact with any of the Services. This information includes your device’s IP address, User’s browser type, operating system, access times, the content of any undeleted cookies that the End User’s browser previously accepted from us, and the referring website address. For more information about cookies and our use of them on the Site and in course of our Services, please refer to our Cookie Policy

    • HOW DO WE USE USER INFORMATION?
    • Please note that we use User Information for purposes of providing the Services and constantly improve them. That includes the following uses:

      • Operating and further developing and improving the Services, including customizing content and information that we may send or display End Users and to the extent possible, personalize your web interactions by our Services. We may provide our End Users, which engage us through our Site or our Customers sites advertisements that are based on their recent browsing history and behavior, as we received from the cookies and tracking technology (as detailed above in section 2).
      • Validation of users as humans and anti-fraud monitoring;
      • For responding to your communications. If you provided us with your email address, and contacted us for an inquiry or request, for example, we will use your contact details and inquiry content to process it and respond and other communications with you;
      • Identify or authenticate your access and use of your account (in case of a Customer Information).
      • Advertising. Some of our third party services may collect non-identifiable information about your interaction with the Service. Such information may be used by such third parties for serving and displaying ads and offers (“Ad/s”) when you browse other websites across the web (“Retargeting”). You will have the choice to opt-out at any time of such type of advertising, directly from the Ad when you encounter it, from the ad setting of the providing third party services.
      • In order to provide our Customers with aggregated activity reports.
      • For any legally permissible purpose in our sole discretion or law enforcement requirement
    • SHARING OR DISCLOSING USER INFORMATION
    • We do not share Personal Information about you with Third Parties, except for the following circumstances:

      • Anti fraud purposes where a third party monitoring body or certifier of such third is require to maintain and audit a black list of IP addresses.
      • Data Storage, Data Centers and Security Platforms (“Processors”); We use third party cloud, data centers and data storage services to store and retain your Information. It means that we send or otherwise share your Information to/with third party entities that are based in the EU and in Israel, for the purpose of storing such information on our behalf, or for other processing needs. Such entities include Amazon Web Services (which privacy policy available at: https://aws.amazon.com/privacy/) and EvoSwitch (which privacy policy available at: https://evoswitch.com/disclaimer/). Our Processors may be based (and their servers may be located) anywhere in the world. We require each such Processor to maintain a strict privacy protection and data security policies, and strict compliance with applicable data protection laws. However, their practices and activities are fully governed by their own privacy policies and the jurisdictions in which they are based.
      • Enforcement. We may share your Information with any third party if we believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce our terms and conditions, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of our Services, system network or technology, our affiliated entities, our users, yourself, and/or the public.
      • Third Party Partners. we may submit non-personal information that is cookie based to advertiser and other third parties in aggregated form for the purpose of providing the with activity reports, market research advertising or other purposes.
      • Merger, Sale or Bankruptcy. In the event that we or one of our affiliated entities is acquired by, or merged with, a third party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In such case, we will require the acquiring entity to post its data practices and provide you with any of your rights as per the jurisdiction of your residency.
      • Other Third Parties. We may send or otherwise share End User Information to/with various third parties that help us with our business operations that help us, operate and improve our Services. These third parties may have their own privacy policies that they adhere to, and we require them to make it available whenever their services are provided. We recommend you revisit such privacy policies when those third parties render their services directly to you. Also, these third parties may be based (and their servers may be located) anywhere in the world.
    • USER CHOICES
    • We believe in keeping the choice in our Customers’ and End Users’ hands, so we try to be transparent with you and let you choose whether you want to engage and interact with our Services subject to this Privacy Policy’s terms. Some Information is collected and required to provide you with the Services and you cannot otherwise be able to use them. In other cases, you can decide to exercise the following rights with respect to your Information, based on the jurisdiction of your residency. For example (where applicable and relevant):

      • Newsletters, Surveys and Promotions; You may choose not to receive future promotional, advertising, or other similar emails from us by selecting the unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving such emails, we may still send you administrative emails to facilitate your use of the Website or Services, unless you request to completely delete your contact information.
      • Cookies and web tracking technologies. you may set your browser to refuse and/or block any cookies from us or third party services, or periodically remove and delete any existing cookie installed. Be aware that in such cases some of the Services’ functionalities would not be properly available.
      • Opt-out. If End User does not wish its Personal Information to be collected, processed or shared for the above purposes, or you wish to refrain from receiving customized content, he may opt out from this use with effect for the future. Please select your preferred recommendation settings below.
        Before Opting Out (disabling EngageYa's cookies), please consider this action may affect your user experience on the websites you visit; for example, you may receive repeated advertisements or native articles despite the fact you already clicked and read them in the past and you will probably receive content and advertisements that are generic rather than customized to your interests.
        End Users may also opt-out of the collection and use of data on mobile applications by adjusting their device settings as follows:
      • iOS Devices: Settings > Privacy > Advertising > Limit Ad Tracking;
      • Android Devices: Settings > Google > Ads > Opt Out of Interest-based Advertising;
      • After the End User has opted out, he will still be able to see Engageya content, but it will not be custom tailored for you.

      • California Privacy Rights. California Civil Code Section 1798.83 permits our Customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are an End User, to date, we do not collect any Personal Information that may identify your so we would not be able to exercise this right and you should read more about our opt out option. If you are a Customer you may sending an email to: privacy@engageya.com.
      • EU Data Subject Rights. Any Personal Information that we may collect according to this Privacy Policy is handled and treated in compliance with the EU general data protection regulation.
      • Canada. If you are a resident of Canada, you are permitted to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, where applicable. To make such a request, please send an email to privacy@engageya.com. If otherwise you have any question about your Personal Information you may contact our compliance team at privacy@engageya.com.
  • LINKS TO THIRD-PARTY WEBSITES
  • We may link to other websites of third-parties that provide useful information/services. Any information User provides on the linked pages is provided directly to this third-party and is subject to that third-party’s provider’s privacy policy. We are not responsible for the content or privacy practices of such sites to which it links. You should learn about the privacy practices of each site before providing them with Personal Information.

  • INFORMATION SECURITY
  • We, and third party services/affiliate entities implement data security systems and procedures to secure the information transmitted, processed and stored in our computer servers and systems. For example, the Site is encrypted by using SSL and so as any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the world-wide network. Therefore, we cannot guarantee that the Services and our servers are immune to unauthorized access to the information stored therein and to other information security risks. If you have any questions about our security and safeguards efforts, you can contact us at: privacy@engageya.com.

  • DATA RETENTION
  • Unless we are instructed otherwise by applicable laws, we retain Information we collect for as long as needed to provide the Services, operate them, monitor them, and to comply with our legal obligations, resolve disputes and enforce our agreements.

  • CROSS-BORDER DATA TRANSMISSION
  • We may transfer your Information (including Personal Information) outside the country in which it is collected or in which you are reside, including to a country that may not offer the same level of protection for Personal Information as the country in which you reside. However, in which case we make sure to place all contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among our third party vendors. If applicable to your type of consuming the Services, by providing Personal Information and using the Services, you expressly consent to the use of such Information in accordance with this Privacy Policy and to the transfer of your Information to another country.

  • CHILDREN’S PRIVACY
  • The Services are not designed to attract children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16. If we learn that we have collected Personal Information from a child under 16, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us in accordance to the contact information set forth below.

  • COMMENTS AND QUESTIONS
  • If you have any comments or questions about this Privacy Policy, please contact us at privacy@engageya.com.


For Data Subjects in the EU
We appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/19616340

Contact GDPR-Rep.eu

GDPR-Rep.eu
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Beaconspark Ltd
Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence:
GDPR-REP ID: 19616340

GDPR-Rep.eu certificate of Art 27 representation