1. Your Consent (PLEASE READ CAREFULLY!)
FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR AND/OR YOUR END-USERS’ PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR AND/OR YOUR END-USERS’ PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILYPROVIDED TO US.
2. Which information may we collect on our users?
We may collect two types of data and information from our Users:
- Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the My6sense Platform. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the My6sense Platform, type of operating system, type and version of browser, keyboard language, screen resolution, etc.
- Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
- Users of the My6sense Platform and/or the Services automatically provide their IP address or other unique identifier (if applicable) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.
- When opening an account, You may be required to provide the following registration details, for the purposes of opening an account and logging in to My6sense Platform: full name, e-mail address, company name, website, phone number and a password.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
3. How Do We Collect Information on Our Users?
There are a few methods that we use:
- We collect information through your entry and use of the My6sense Platform or Services. In other words, when you are using the My6sense Platform and Services we are aware of it and may gather, collect and store the information relating to such usage.
- We collect information which you decide to provide us voluntarily. For example, we collect Personal information when you contact us through the contact form or when you open an account.
- We collect information via our partners. Certain of our partners with whom the My6sense Platform and Services are connected to, collect information about users, and transfer that information to us, so that we can provide and improve our Services.
We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.
4. What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to:
- Use it for statistical and research purposes and for customization and improvement of the My6sense Platform and Services.
- Enhance the User’s experience while using the My6sense Platform and Services.
Personal Information is collected in order to:
- Facilitate the general operation of the My6sense Platform and Services.
- Provide and personalize our Services to our Users.
- Verify the User’s identity when he/she signs in through his/her account.
- Provide Users with updated information regarding our products and services.
- Be able to contact Users for the purpose of providing them with technical assistance, billing for their use of the Services and support.
- Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of the My6sense Platform’s Users as well as in order to safeguard the My6sense Platform.
Note to our Users in the EU:
In order for My6sense to collect and process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing. Please note that the processing may be justified on the basis that:
- the collection and processing is based on your consent;
- the collection and processing is necessary for your performance of services offered to you;
- the collection and processing is necessary to enable My6sense to comply with a legal obligation (e.g. disclosure of information to authorities); or
If you have any question or require any clarifications regarding the basis for processing your Personal Information, please contact us.
5. Sharing Information with Third Parties
For avoidance of doubt, My6sense may transfer and disclose Non-personal Information to third parties at its sole discretion, and for any purpose, including without limitation for statistical, analytical and research purposes and for customization, development and improvement of the My6sense Platform and Services.
6. Deletion or Modification of your Personal Information
In any event, if for any reason you (or any person) wish to delete or modify Personal Information, you can do so within your account. Otherwise, please send us an e-mail with adequate detail of your request to: email@example.com and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected and/or when necessary to comply with My6sense’s legal obligation, dispute resolutions and the enforcement of My6sense’s agreements, all as permitted under any applicable privacy laws. Please note that we are not obligated to store Personal Information for perpetuity and disclaim any liability arising out of, or connected to the destruction of Personal Information. You should be aware that it is not always possible to completely delete or remove your information from our databases due to the conduction of backups.
Aggregated and/or anonymous information derived from your use of the My6sense Platform or Services may remain on our servers indefinitely.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law) with respect to the processing of your Personal Information:
- Right to access: you may have the right to request a review of your Personal Information held by My6sense.
- Right to erasure: under certain conditions, you may be entitled to require that My6sense will delete or “block” your Personal Information (e.g. if the continued processing of a specific data is not justified).
- Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information from My6sense to another entity).
- Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
- The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
- Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact My6sense at firstname.lastname@example.org.
In order to provide you with our Services and, inter alia, serve advertisements to publisher’s websites, application or other properties (including without limitation, any content contained therein) (collectively, the “Properties”), and in order to constantly improve our Services, we and our advertisers may collect, use and disclose certain data related to the end-users of the publisher’s Properties (the “End-User(s) Data” and the “End-Users”, respectively).
Which information we may collect on Publisher’s End-Users?
End-User Data consists of the following types of information:
- End-Users Non-personal Information: Non-personal Information is any unconcealed information which does not enable identification of an individual End-User. Non-personal Information is available to us and may be available to our advertisers while End-Users are accessing or using the publisher’s Properties. Non-personal Information which is being gathered may consist of technical information, behavioral information or aggregated information, and may contain, among other things: technical data, e.g. type of operating system and configuration, screen resolution, screen density, web browser software, the activity of the End-User on the Properties, End-User’s ‘click-stream’, usage patterns and other statistical data, the time the End-Users were engaged with the advertisements in the publisher’s Properties, etc.
- End-Users Personal Information: We and our advertisers may collect the following Personal Information: the End-User’s IP address, geo-location (country, region, city) and/or other behavioral information related to a particular End-User’s engagement with advertisements on the Properties. However, please note that the IP address collected by My6sense on behalf of our customers, is anonymized as soon as technically feasible by changing its last octet to zeros.
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
- What are the Purposes of the Collection of End-User Data? We and our advertisers may use the End-User Data in order to provide the publisher the Services, i.e., for the purpose of displaying advertisements of our advertisers on the publisher’s Properties and for facilitating the general operation of the My6sense Platform, including without limitation the recommendation engine included in the My6sense Platform that matches native ads to both page content and End-Users, in real-time. For example, we will collect Personal Information in order to determine geo-location information from which the End-User is connected to the Internet in order to serve advertisements through the My6sense Platform and/or Service based on such End-User’s location. We may use the web browsing information in order to show the End-User specific advertisements that we or our advertisers think will be of interest for the End-User (i.e., to match relevant advertisement to End-Users). In addition, we and our advertisers may collect End-User Data in order to (i) create statistics and other aggregate information and analysis with respect to the publisher’s End-User’s engagement with advertisements which are served to the Properties through the Service; (ii) use it for statistical, analytical and research purposes and for customization, developing and improvement of our Services; (iii) for general campaign performance in order to report to advertisers and demand side partners; (iv) to determine the amounts to bid, pay or offer for impressions, clicks or units of ad-inventory; and/or (v) detect fraudulent activities that occur while the publisher’s End-Users are engaging with advertisements on the Publisher’s Properties.
- Sharing End-User Data with Third Parties. We share End-Users Data in order to fulfill the purposes mentioned above, including with our advertisers and other demand-side partners.
- Deletion or Modification of End-User Data. We usually have no direct relationship with the publisher’s individual End-Users and we do not send communications to the publisher’s End-Users. We will comply with all applicable laws with respect to deletion and modification of personal information. Aggregated and/or anonymous data may remain on our servers indefinitely.
- Children/Minors End-User Data. The publisher agrees that it will not use the My6sense Platform and/or Services in connection with any Properties directed to Minors. The term “Minor” shall mean a Child as such term is defined under the Children’s Online Privacy Protection Act of 1998 and the rules promulgated by the Federal Trade Commission (FTC) under that Act, including but not limited to the Children’s Online Privacy Protection Rule 16 C.F.R. Part 312 (the “COPPA”) or any other under-age individual as defined by applicable children protection legislation in any relevant jurisdiction. The publisher will (i) notify My6sense in writing of any Properties which are or may be considered as a “Child Property” under the COPPA, and (ii) to the extent required by applicable laws, implement reasonable commercial means within the Properties for identifying Minors when the Properties are not primarily directed at children under such age; all in order to enable My6sense to block collection of information from Minors. If the publisher learns that any information transferred to us via the Services includes Personal Information collected from Minors, the publisher is hereby requested to inform us immediately and we will delete that information as quickly as possible. With respect to End Users in the European Economic Area, we do not collect any Personal Information that we can know or verify is related to a person under 16 years of age.
- “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services. We may provide advertisements to publisher’s End-User’s based on their browsing behavior. The publisher should notify its End-Users that we and our authorized third party advertisers may serve the publisher’s End-Users behavioral advertisements. Please note that activation of any applicable “Do-not-track” settings on the End-Users’ web browser will normally cease all tracking activities by My6sense Platform and Services, depending however on the type and functionality of this browser’s option, and may not cease all tracking activities by all our authorized third party advertisers. My6sense is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
- End-Users may request to delete, transfer or access any Personal Information stored by My6sense about them. In order to do so, please email: email@example.com.
The My6sense Platform and/or the Service are intended for Users over the age of sixteen (16). My6sense does not intend and does not knowingly collect Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the My6sense Platform. If we learn that we unlawfully collected Personal Information from children under the age of sixteen (16) we will delete that information as quickly as possible. Please contact My6sense at firstname.lastname@example.org if you have reasons to suspect that My6sense collected Personal Information from children under the age of sixteen (16) and will delete that information as quickly as possible. It is hereby clarified that the documents you provide us access to may include information regarding children under the age of sixteen (16) only in the event that the legal guardian of such child has agreed to such use, all as required under any applicable laws.
We take reasonable measures to maintain the security and integrity of the My6sense Platform, Services and End-User Data that we collect and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. The Personal Information is hosted on the Amazon hosting servers, which provide advanced strict security standards (both physical and logical). In addition we employ highly secure services design and implementation using encryption and architectures mechanisms. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. MY6SENSE SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.
10. Third Party Service Providers
11. Links to Third Party Websites
12. Cookies and Other Tracking Methods.
13. International Data Transfer
In order to facilitate the operation of the My6sense Platform and to provide the Service, we may transfer and/or disclose information collected about you and the publisher’s End-User, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your and the publisher’s End-Users’ jurisdiction, and you and the publisher’s End-Users consent to such transfer of information.
15. Got any Questions?