Privacy and Data Protection Agreement

Advertum Tech OÜ (hereinafter Advertum) is serious about respecting the right of each user of our Advertum service to maintain data privacy and takes measures to protect any information provided to us through the service. Please review the contents of this privacy and data protection agreement («Agreement»). It sets out Advertum's international privacy and data retention policy and details how data is collected and processed. If during your visit you decide to register or submit data, you hereby give your consent to Advertum to use such information in accordance with the terms of this Agreement.

This agreement informs users about data rights and measures taken by Advertum to ensure privacy and protection.

If you have any questions about the data, or about related procedures and policies, please contact us at the address below.

For more information on the subject you are interested in, please follow the link in the table of contents.

Table of contents

1. 1. List of data and how to submit it through this website
2. 2. Privacy and data protection principles
3. 3. Purposes for using user data
4. 4. Targets and list of people who have access to the data
5. 5. Viewing, checking, changing and deleting data
6. 6. Data transmission purposes
7. 7. Cookies
8. 8. Position on spam emails
9. 9. Data retention times
10. 10. Policy on Children Visiting Our Websites
11. 11. Links to third-party websites
12. 12. Changing the terms of this Privacy Agreement
13. 13. Further information on data privacy issues
14. 14. Terms and definitions

1.1. Only the personal information that the user provides to us voluntarily is collected. This data is necessary to ensure the correct operation (and improvement) of our service. We collect data about users on public pages of social networks used for authentication in the Advertum service which are public information, such as name and surname, year of birth or user's avatar given in the social network profile, and data is transmitted only if it is publicly viewable by the user. The data will not be saved in the service, but will be uploaded automatically using automatic social networking protocols.

1.2. Users may send us their email address, name, phone number to ensure safe use of Advertum service, participation in contests or surveys or to receive news about developments on Advertum they are interested in.

2.1. Advertum takes all necessary measures to protect any data provided to the company. Only authorized employees of Advertum Group, authorized employees of third party companies (i.e. service providers) or our business partners who have signed a privacy and data protection agreement have access to data. All Advertum employees with access to data must adhere to the privacy and data protection policy within this document. In order to ensure data privacy and data protection, Advertum maintains an appropriate IT environment and takes all measures necessary to prevent unauthorized access (hacking).

2.2. See question 4 - Who accesses data in Advertum and for what purposes?

3.1. Data is used only for the purposes for which it is provided to Advertum. The information may also be used to secure leads, administer, support and provide feedback at the service level, as well as to prevent breaches of confidentiality, legal regulations or contractual terms.

4.1. Advertum's policies regarding direct marketing via email, the consumer's rights at any time to DISCLAIM contracts with Advertum in the form of direct marketing via email, and the consumer's rights to delete data from our systems are described in paragraphs 8 and 5, respectively.

4.2. Advertum has the right to share the submitted data with third parties, but only under strict observance of the conditions set out below.

4.3. Data may be transmitted to third parties (such as our Internet service providers) that operate this website. Some of these business partners may be located outside of the country from which the visitor is accessing the website. These business partners must provide the same levels of data protection as Advertum and, where applicable, sign agreements imposing appropriate legal obligations regarding privacy and data protection and data processing only in compliance with certain Advertum guidelines.

4.4. In addition, data may be shared with government authorities where Advertum is compelled to do so pursuant to the requirements of any applicable law, or where in our opinion such action is necessary to comply with the law, to comply with lawfully justified requirements, or to protect the rights of Advertum, its customers and consumers.

5.1. The data is stored at Advertum in a form that allows identifying the data subject no longer than the purpose of its processing, and it must be destroyed after achieving the purpose of processing or if it is no longer necessary to achieve it.

5.2. The user may request to delete, correct or verify data by sending an email or letter to the address listed in the contact information.

6.1. Advertum is an international company and, therefore, data may be transferred outside the country. Data may be transferred to countries where the level of privacy protection under the law may differ from the level provided in the country where the data is transferred. Advertum takes all measures necessary to ensure the protection of confidentiality of private information both in the process of data transfer and in the place where the information is sent.

6.2. The primary provider of Advertum's website services acts in accordance with a contract imposing appropriate legal obligations on it. This provider ensures a high standard of data protection, acts (among other conditions) only in accordance with Advertum's instructions and guarantees to take all technical measures necessary for the safe storage of data for the entire period envisaged.

7.1. Advertum uses tracking technologies (cookies) to collect data such as browser type or operating system, referring page, website path, Internet service provider domain, etc. in order to obtain general information about how the website is used by visitors. Cookies enable us to tailor this Web site to the needs of its visitors.

7.2. Advertum retains all information collected through the use of cookies in a non-personally identifiable format. Information collected through cookies may not be disclosed to third parties outside of Advertum. This information will not be shared with unauthorized third parties.

7.3. Cookies in your computer's memory contain the IP address of your computer, not the user's name. After the session ends, the information contained in the cookies is no longer available to Advertum.

7.4. Make sure that your computer is set up to allow cookies. Depending on your browser setting, you may be warned about the use of cookies or you may choose not to use cookies, but if you do, you may not be able to access all of the functions of this site. For information regarding browser settings, please use the help function. Cookies are not necessary to use many features of this and other Advertum websites or to navigate within these websites. Keep in mind that if you use multiple computers in different locations, you must set the appropriate browser settings to handle cookies on each computer.

8.1. Spam is email that contains advertising or marketing-related material without prior approval from the recipient.

8.2. Advertum is NOT involved in spamming. Moreover, Advertum uses anti-spam tools within Advertum to protect its employees from receiving unsolicited emails. Advertum will not use data (including email address) for direct marketing or follow-up contacts without the user's explicit consent. Additionally, Advertum does not share data with any third parties (other than Advertum) who may use the data to send spam.

8.3. Advertum websites provide the ability to receive marketing information via email. Each email sent by Advertum provides an opt-out option for emails with marketing information at any time.

8.4. If for any reason a consumer believes that an email received from an Advertum member company contains spam, please inform us immediately at the email address below.

9.1. Advertum may retain information obtained through this website in company databases, such as customer databases. Advertum data should only be retained for as long as necessary to answer inquiries or resolve problems, provide improved or new services, and as required by local law. This means that data may be retained for a certain period of time after a customer stops using Advertum services or visiting this website. After a certain period of time, data is deleted from all Advertum systems.

9.2. We remind you that the company has the right to delete consumer data at any time.

10.1. We understand the critical importance of ensuring the privacy and protection of the data provided by children who visit our Web sites, and believe it is important to encourage parents or guardians to take an interest in their children's online activities, monitor their online activities and participate in our activities together.

10.2. We do not knowingly involve children under the age of 16 in the data collection process. We collect information on these websites in compliance with all applicable local laws and regulations regarding children's privacy rights. If a parent or guardian consents to the release of any information from children, only information necessary for the enrolled child's participation in the program will be collected.

Special treatment for children under 16

10.3. If you are under the age of 16, we suggest that you talk to your parent or guardian BEFORE submitting your information on the Advertum websites. If anything in this section seems unclear to you, ask your parent or guardian for help.

A special appeal to parents of children under 16

10.4. We recommend that parents/guardians regularly monitor children's use of email functions and other online activities.

10.5. Make sure that your children do not provide Advertum with any personally identifiable information when they visit the website online without your consent.

10.6. You may request that any information provided by your child be deleted by sending a request for deletion by mail, e-mail, or fax to the address listed in the contact information.

11.1. We link to other websites in order to provide consumers with information of interest. These third-party websites are not under our control and are not subject to this Agreement. When accessing other Web sites through the links provided, be aware that the operators of those Web sites may collect data. Make sure you agree to the privacy and data protection policies of these third-party websites before providing any information.

11.2. Advertum makes every effort to provide equivalent measures on all related third-party websites to protect data, but we cannot be responsible for the actions or level of privacy of these third parties.

12.1. Advertum may make changes and corrections to this Agreement from time to time. We recommend that you periodically review the text of this Agreement to keep track of such changes and their possible effects.

13.1. For more information regarding legal requirements and conditions on the Advertum website, please contact us at the address below.

14.1. Advertum uses the following basic concepts:

data — any information relating to a defined or identifiable individual (data subject) based on such information, including his name, surname, year, month, date and place of birth, derived from data specified for publication to the general public in a social media profile;

operator — any information relating to a defined or identifiable individual (data subject) based on such information, including his name, surname, year, month, date and place of birth, derived from data specified for publication to the general public in a social media profile;

data processing — actions (operations) with data, including collection, systematization, accumulation, storage, clarification (update, change), use, distribution (including transfer), depersonalization, blocking, destruction of data;

data distribution — Actions aimed at the transfer of data to a certain circle of people (data transfer) or to make data available to an unlimited circle of people, including the disclosure of data in the media, placement in information and telecommunications networks or providing access to data in any other way;

data usage — Actions (operations) with data performed by the operator in order to make decisions or perform other actions that have legal consequences with regard to the data subject or other persons or that otherwise affect the rights and freedoms of the data subject or other persons;

data blocking — temporary cessation of collection, systematization, accumulation, use, dissemination of data, including their transfer;

data destruction — temporary cessation of collection, systematization, accumulation, use, dissemination of data, including their transfer;

anonymization — actions that make it impossible to determine whether the data belongs to a specific data subject;

data information system — information system, which is a set of data contained in a database, as well as information technology and technical means that allow the processing of such data with or without the use of automation tools;

data privacy — The operator or other person accessing the data is required to prevent its dissemination without the consent of the data subject or any other legal basis;

cross-border data transfer — transfer of data by the operator across the state border to a foreign state authority, natural or legal person of a foreign state; publicly available data - data to which access is granted to the general public with the consent of the data subject or which, in accordance with federal laws, are not subject to the requirement of confidentiality.

User — a citizen who intends to order or purchase or who orders, purchases or uses goods (works, services) exclusively for personal, family, household and other needs not related to entrepreneurial activities.