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Privacy policy

This Privacy Policy applies to user data collected, stored, or processed by Primax Digital OÜ (“we,” “us,” “our”) for providing the ad-serving services.

Of course, we comply with the legal provisions of the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and other data protection provisions. For Primax Digital OÜ, the protection of personal data is very serious and we strictly comply with the data privacy laws.

Your data is processed by Primax Digital OÜ (registration number: 16528565, address: Harju maakond, Tallinn, Kesklinna linnaosa, Narva mnt 7-636, 10117) (service provider and data controller within the meaning of the General Data Protection Regulation). Our services are intended for the general public and not for children. We do not knowingly collect personal information from users who are considered children under their respective national laws. This document also applies to technologies that we embed within the framework of our ad-serving services on third-party websites and through which we receive information about you.

 

What is personal information?

According to Art.4 No. 1 GDPR, personal data is any information relating to an identified or identifiable natural person, therefore can be used to obtain personal or factual details about the data subject (such as name, address, telephone number, date of birth or e-mail address). Information that cannot (directly or indirectly) be associated with a natural person (or only with disproportionate effort), for example, anonymous information, is not personal information.

 

What personal data we collect

We specialize in displaying ads that are relevant to you.

Primax enforces generally accepted industry security standards for the programmatic platforms to protect the information both during transmission and once it is received.

We process the information through our programmatic platform on behalf of our clients and under their instructions specified in our contractual agreements (Art. 28 (3), GDPR).

The information we collect serves, among other things, to analyze the use of a website in reference to advertising space, visibility measurement of advertising and / or contents of websites, and analyze fraud.

 

Data is collected by using our services:

Through IP, browser and / or app we capture the approximate geographic location to verify the customer’s correct geographic delivery.

We collect device-specific information, including GPU, browser, operating system, the device itself (Smartphone, Tablet, Notebook, etc.)

Details of how you have used something in relation to the particular analysis. This can be the use of an internet site, watching a video or an advertisement.

IP-Address (illegible, not personalized)

Browser specific information like language, MIMEs, plugins, toolbars, extension, compatibility, version and status

 

Information about the ads can contain:

  • the details of the ad delivered (e.g. advertiser’s name, type of advert, etc);
  • the website or the app where the ad was delivered;
  • your interaction with the ad (i.e. whether you clicked, hid, muted or otherwise interacted with the ad);
  • whether you performed certain actions after clicking on the ad (e.g. downloading an application, making a purchase, etc).

This allows us to show advertising that is more relevant to you. We do not at any point collect contact information such as your name, address, phone number, email address, credit card information, or anything else that can allow us or our clients to contact you directly. There is no way for us to know who you are. We only collect data from our trusted data partners and do not collect data from public sources.

For us to process your data, you will have already accepted cookies or similar technologies from one of the publishers or advertisers we work with. You can change your preferences at any time as set out in this Policy below.

 

Why we use it

Primax Digital OÜ uses this information for online marketing purposes throughout its programmatic platform. In detail, we use the information to predict users’ interests and preferences for interest-based advertising:

  • enable advertisers to customize ads to a particular location and users’ location behavior,
  • determine how users respond to certain ads,
  • enable cross-device targeting in order to serve or measure advertising on related devices
  • report aggregated statistics regarding, for example, the effectiveness of digital advertising campaigns and
  • provide, operate, manage, maintain, and enhance the programmatic platform.

The collected data is used for the following purposes:

  • Information storage and access

The storage of information or access to information that is already stored on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.

  • Personalization

The collection and processing of information about your use of this service to subsequently personalize advertising for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, which inform future selection of advertising.

  • Ad selection, delivery, reporting

The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. This does not include personalization, which is the collection and processing of information about your use of this service to subsequently personalize advertising for you in other contexts, such as websites or apps, over time.

 

Legal basis

Our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. We collect and process information from you only where we have your consent (Art. 6 (1) lit. a) GDPR), where we need the information to provide our contractual obligation to you (Art. 6 (1) lit. b) GDPR) or where we have a legitimate interest to do so.

We also process the information described above through our programmatic platform on behalf of our clients and under their instructions specified in our contractual agreements (Art. 28 (3) GDPR).

The legal bases for the processing of your data could be our legitimate interest in accordance with Art. 6 (1) lit. f) GDPR, e. g. our business interests in improving our services so that we can better understand your needs and expectations and thus improve the services we provide; to prevent fraud and to ensure that websites are used completely and without any fraudulent behaviour; to ensure and guarantee the security of our services, making sure that our offer is technically secure and properly functioning; to ensure and enforce our contractual requirements and claims.

Legal reasons in accordance with Art. 6 (1) lit. c) GDPR, if the collection, storage, transfer, or other processing of data is prescribed by law or processing, is necessary to fulfill our legal obligations.

In the event that data is processed for a purpose other than the one specified during data collection, a compatibility check takes place in accordance with Sec 6. (4) GDPR. Further processing is only permitted if the original purpose is compatible with the new purpose or is permitted based on a separate legal basis. Recognized compatible purposes include the assertion, exercise, and defense of civil claims unless the data subject has an overriding interest. In this case, we will inform you about the change in purpose. If the new purpose is incompatible with the purpose stated during collection, the new collection will take place based on a new legal basis. Again, we will inform you about the change of purpose in this case.

If you wish to learn more about specific legal ground(s) we rely on to process your information for any particular purpose (including any legitimate interests we have to process information), then please contact us using the details provided below.

 

Data Sharing

We provide insights to our advertisers and publishers in the form of aggregated data. This does not include any individual personal data.

Non-aggregated data may be stored by third parties such as data-centers and hosting providers who provide their services on our behalf. These companies are authorized to use the information we provide only as necessary to provide these services to us.

Additionally, we work with external data processors, to which we provide certain data in order to provide our services. In order to adapt the selection of advertisements to be displayed to your interests and evaluate them, we use cookies and other similar technologies in the advertising content, over which we collect anonymized data about you, if you have surfed the respective third-party website or have interacted with the advertising displayed, e.g. your IP address. We also use technologies that third parties provide us with for these purposes. In this case, the respective third-party provider receives information about you. You will find more information on data protection and how these companies process your data for each service on the websites from the companies mentioned:

 

Children’s Information

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal data about children under 13.

 

Data Security

The security of your information is important to us. Primax has implemented security measures, including physical, electronic and administrative safeguards, to prevent the loss, misuse, and alteration of the information that we collect, but we make no assurances about our ability to prevent such loss, misuse, to you or any third party arising out of any such loss, misuse, or alteration.

 

Supporting the IAB’s Transparency and Consent Framework

We fully support the IAB’s Transparency and Consent Framework and can work with our partners to implement that framework. Our company is also listed on the https://iabeurope.eu/vendor-list/.

 

We are fully committed to being GDPR compliant and working with our partners to support their GDPR compliance efforts now and in the future.

 

OPT-OUT of your data processing

If you do not want you to be processed by a programmatic platform, click here, and we will make sure the information is deleted.

After pressing the button, the selection of ads will be carried out without taking into account the actions you take on the Internet.

Please note that by opting out, you still will receive advertising when you visit any websites.

  • Other Companies

The online advertising industry also provides websites from which you may opt-out of interest-based advertising from other companies that participate in industry self-regulation. You can access these websites, and learn more about interest-based advertising, at www.youronlinechoices.com at www.aboutads.info/choices and at www.networkadvertising.org/choices.

  • Mobile Opt-Out

If you are using a mobile device, you may be able to opt-out of receiving interest-based advertising through your device settings. We provide the following descriptions solely for informational purposes. For additional information and up to date methods of opting out, you should consult your device settings and instructions provided by device manufacturers.

  • Opting Out on iOS Devices Such as iPhones, iPads or iPods

If you have an Apple device, you can opt-out of our behaviorally targeted advertising services by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’. You can do this by clicking on Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON’. Our platform is designed to respect your choice and not use the information to provide interest-based advertising when this setting is ON. Again, you should consult Apple’s support web pages and instructions for the most current applicable settings.

Opting Out on Android Devices

If you have an Android device and would like to opt-out of our behaviorally targeted advertising services, you may do this as follows:

  • Open the Google Settings app on your device
  • Select Ads
  • Either “Reset advertising ID” or
  • Opt-out of interest-based ads

Our platform is likewise designed to respect these choices transmitted by your Android device. Again, however, please consult Google’s settings and instructions for the most current settings information.

 

Changes to the Privacy Policy

If we decide to change our privacy policy, we will post the changes here.

 

Contact us for information about how we use your personal data

If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at Primax Digital OÜ (registration number: 16528565, address: Harju maakond, Tallinn, Kesklinna linnaosa, Narva mnt 7-636, 10117). Or, email info@primax.digital

 

Complaints will be dealt with by the Data Protection Officer and will be responded to within 30 days.