PRIVACY POLICY

Adsmurai privacy policy and data protection

Last update: May 2018

1. Presentation and right to information

ADSMURAI (registered as ADSMURAI S.L. with registration number [NIF] ES-B66216482) takes the protection of your privacy and Personal Data very seriously. We are committed to protecting the privacy of individuals who visit our website www.adsmurai.com (visitors), individuals who use our services or products (customers), and individuals who register to attend our corporate events (attendees) (collectively hereinafter “Data Subjects” or “Users”).

The purpose of this Privacy Policy is to demonstrate our robust commitment to the Data Subjects’ right to privacy and data protection. This Privacy Policy outlines how we handle information that can be used to directly or indirectly identify a Data Subject (the “Personal Data”) and describes our practices in relation to the use of our website and the related applications and services offered by us (collectively, the “Services”), as well as Data Subjects’ choices regarding their rights such as use, access and rectification of Personal Data.

We act as a controller with respect to the information we process in connection with our business relationships. For example, we are the controller in relation to Data Subjects’ contact details and other commercial Personal Data (. On the other hand, we may also act as a processor of Data Subjects’ Personal Data when our customer and business partners engage us to process Personal Data on their behalf, for example in connection with the provision of the Services. We may also act as a processor in certain circumstances when our customers use third party service providers in connection with our Services (e.g. Facebook, Twitter or Google among others). When we act as the processor, we process the data in accordance with applicable privacy laws and the data processing agreement entered into with the controller, where applicable. In such a case, please refer to the Privacy Policies of controllers for further information on the processing of Personal Data.

The most important point to understand here is that the only personal data we process is data in connection with our business relationships (product and services). We do not process Personal Data about those individuals seeing ads in social media networks.

As such, if you are looking for details regarding the privacy policy of Facebook, Twitter or Google (among others), we invite you to visit their respective resource centers:

Facebook: https://www.facebook.com/policy.php
Twitter: https://twitter.com/es/privacy
Google: https://policies.google.com/privacy

2. Processing of Personal Data

We process Personal Data of Data Subjects to offer the Services, including the processing and execution of demo requests relating to the Services, and to contact and market our Services to the participants of our business events and to contact and send marketing material to the visitors of our websites who submit us their information in a form. Personal Data may be used for direct marketing, including, where applicable, by electronic means unless objected by the Data Subject.

Further, Personal Data may be used for invoicing and to send important information to the Data Subject e.g. regarding changes of applicable fees, price list and conditions, or to contact the Data Subject and provide information customized Services according to the interests of the Data Subject.

We process Personal Data on the following basis:

· for the performance of the contract between us and the Data Subject (Article 6.1(b) of the GDPR);
· for the purposes of our legitimate interests related to the customer and business relationships between us and the Data Subjects (Article 6(f) of the GDPR);
· to comply with legal obligations applicable to us (Article 6(c) of the GDPR), such as corporate and accounting.

We may ask for Data Subject’s consent for the processing of certain type of Personal Data (for example for a campaign). When collecting such consents, we inform the Data Subject of the respective purposes of processing and such processing is conducted only when appropriate consent is received. We may ask for certain Social Media Networks (including but not limited Facebook, Instagram, Twitter, YouTube)) permissions allowing us to perform actions with the Data Subject’s account and to retrieve information, including Personal Data, from it. This allows our Services to connect with the User's account on the Social Media network, provided by the third-party platform. In this context, the following permissions may be asked: About Me, Access Rights (including but not limited to Facebook Ad Account Access, Business Manager Access, Twitter Accounts, Google AdWords Accounts), App Notifications, Contact Email, Manage Advertisements, and Manage Pages. For more information about the Social network permissions, please refer to the individual platform permissions documentation and Data Policy.

3. Personal data we collect

Personal Data processed by us is mainly obtained directly from the Data Subject. Provision of such Personal Data is necessary to use and purchase our Services, to accommodate Data Subject’s request for information relating to our Services and to organize communication in relation to our business events. We may not provide the Services to a Data Subject that refuses the processing of his/her Personal Data. We process also Personal Data accumulating from the use of our Services (including data collected under our cookie policy), and obtained from third party sources related to the Services. Personal Data may be updated and supplemented by collecting data from private and public registers.

We collect the following Information in conjunction with the Data Subject's:

Customers: We collect company name, fiscal address, billing information, email, telephone number, Internet Protocol (IP) address and (if available) the social media user name of those employees that ADSMURAI interacts with or has interacted with.

Social Media Users: We collect information from Social Media Users such as public uploads and posts, including publicly posted photographs. With such assets, we process name, social media username, physical address (if available), email-address (if available), IP address, and geolocation (if available).

End Users: When End Users interact with our web sites or the user galleries we collect IP address and date/timestamp. If an end-user buys products directly from a Customer digital property, ADSMURAI additionally collects purchase information (including purchased product ID, transaction ID, transaction price, date of purchase, unique ID that our Customer may have assigned to such End User), email-address and username (if provided by End Users to Customers).

Visitors and attendees: we collect name, phone number, email address, usage data and cookies or any other information the user can provide via form (in website). If you attend any of our corporate events in our offices we would collect also your personal data (name, email address and phone). We would also collect your information when you submit your resume via www.adsmurai.com/en/careers such as your email, phone number, content of your resume and any other information you chose to share with us, in order to properly process your application.

In addition, we may process various other types of Personal Data generated in connection with the Data Subject’s use of any third-party services and applications as specified in the privacy policy of such third-party service or application. We do not collect sensitive information (Personal Data of special categories).

4. Use of personal data

Customers: We use the Personal Data we have collected from you to provide you with information about and access to our Services, to communicate with you about updates, maintenance, outages or other technical matters concerning our Services, to respond to your questions or inquiries regarding our Services and to allow you to download information, all to fulfil our contractual obligations.

Social Media Users: We only process Personal Data we collect from you to provide the services for which our Customers have engaged us. Our Customers to whom you have submitted content through the “Adsmurai Marketing Platform“ (AMP®) or whose brand hashtags, @brand mentions or branded location tags you have included in your social media posts, may use your username or email address to communicate with you, in addition to using your photo. IP and geolocation are used to filter content by region, country or other local area. Such data is used with your consent only.

End Users: We process the Personal Data described above to allow our Customers to analyze with which digital assets you interacted prior to purchasing a product from a Customer digital property after interacting with the user galleries on those digital properties.

Visitors and attendees: We process the Personal Data in form of Database in order to send you updates from our products, services or in form of a monthly Newsletter so we can keep you up to date of all changes occurred in the sector and our social media ecosystem.

5. Direct marketing and how you can manage your preferences

We may use your Personal Information to let you know about our products and services that we believe will be of interest to you. We may contact you by email, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

For the purpose of protecting your privacy and to ensure you have control over how we manage marketing with you:

· we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
· you can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing, by following the 'unsubscribe' link you will find on all the email marketing messages we send you. Alternatively you can contact us at privacy@adsmurai.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email).

6. Disclosure of personal data

For the purposes stated in this Privacy Policy, Personal Data may be disclosed, when necessary, to authorities, other companies within the same group of companies as us, companies which the group cooperates with and to other third parties, such as third-party service providers used in connection with our Services and services related thereto.

7. Retention of personal data

We will store your Personal Information for as long as is reasonably necessary for us to adequately provide you with the services included in the Website and Platforms, and for any additional purposes for which it was collected (for example, in order to respond to a query or compliant), as explained in this Privacy Policy.

In some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

8. Data subjects rights

Data Subject has a right to request from us:

· access to and rectification or erasure of Data Subject’s Personal Data;
· for restriction of processing concerning the Data Subject or to object to processing; and
· to receive, under certain preconditions,

Upon request, weI will provide you with information about whether we hold any of your Personal Data and, if that is the case, what Personal Data we hold. If your Personal Data changes, or if you wish to exercise your right to be forgotten, you may correct, update, delete or deactivate your information from our records by (for Customers) logging into your account and making the appropriate changes or emailing your Account Manager directly, or (for Social Media and End Users) contacting ADSMURAI at privacy@adsmurai.com.

9. Security Safeguards

Securing the integrity and confidentiality of Personal Data. We have taken adequate technical and organisational measures in order to keep Personal Data safe and to secure it against unauthorized access, loss, misuse or alteration by third parties, such as encryption, access controls, firefalls. Nevertheless, considering the cyber threats in modern day online environment, we cannot 100% guarantee that our security measures will prevent illegally and maliciously operating third parties from obtaining access to Personal Data and the absolute security of that information during its transmission or its storage on our systems.

10. Changes to this policy

We may make changes to this Privacy Policy at any time by giving Policy on the website and/or by other applicable means. It is highly recommended that Data Subjects check this Privacy Policy and the website every now and then, referring to the date of the last modification listed at the top of this page. If a Data Subject objects to any of the changes to this Privacy Policy, the Data Subject should cease using the Services, where applicable, and can request that we remove the Personal Data, unless applicable laws require storage of the Personal Data. Unless stated otherwise, the then-current Privacy Policy applies to all Personal Data we have about Data Subjects.