WHO IS FLYWEEL?
We at FlyWeel market an advertising solution for both advertisers and publishers. We help publishers and advertisers to display personalized content on websites, apps and other online media, which are named ‘publishers’. If you have given your consent the publisher, we will collect and share your personal data in order to allow the publisher display ads that are tailored to your interests.
WHAT INFORMATION WE RECEIVE FROM PUBLISHERS?
If you provide your consent to the processing of personal data, we will receive the following information from the publisher:
- Analytical information: IP Address, browser type, language, operating system.
- Contextual information (which does not identify you): webpage content, URL, keywords and tags of content displayed on the publisher’s website.
If you do not provide your consent – we will not collect personal data about you. We will only collect contextual information.
If you are in the European Union, you have the right to:
- Access personal information about you that we store on our systems;
- Update or correct or erase the personal information about you that we store on our systems;
- Withdraw your consent to the processing of personal information about you by FlyWeel.
Please note that this Policy covers our privacy practices on general matters. Each publisher or advertiser will have additional privacy policies explaining its own specific privacy practices related to your personal data (“Third-Parties Policy”). You should also read these Third-Parties Policies.
DATA WE PROCESS ON BEHALF OF OUR CUSTOMERS
We collect personal information on behalf of publishers who use our Solution. We only collect information we need to provide our services.
We process analytical information about your use of the Publisher’s website.
When you visit publishers’ websites or mobile applications, we will receive the following information:
- Analytical information: your IP address from which you accessed the publisher’s website, time and date of access, type of browser used, operating system, language and links clicked.
- Webpage contextual information: webpage content, URL, keywords and tags of content displayed on the publisher’s website.
We also process non-personal information about the webpage.
The overall personal data outlined above will be referred to as the “Information“.
HOW WE USE PERSONAL DATA
We use the Information to provide you with ads personalized to your interests.
Subject to your consent to the Publisher, we profile your Information in order to serve you with personalized ads that may suit your interests.
You may opt-out from personalized services by sending us an email.
You may ‘opt-out’ of profiling your Information for personalized ads at any time by sending an email to email@example.com.
The legal basis under EU law for collecting, processing and profiling your Information for personalized ads, is the explicit consent you provided to the Publisher.
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS
We will not share your information with third-parties, except in the events listed below or when you provide us your explicit and informed consent.
We share your Information with the ad networks who allow us to serve you with personalized ads.
We will share your Information with ad networks we are engaged with (“Affiliates“), to operate our Solution and serve you with personalized ads. Affiliates are obligated to use your Information only as necessary to provide personalized ads.
The legal basis under EU law for this processing is the explicit consent you provided to the Publisher.
We share your Information with our service provider helping us operate our business.
We will share your personal information with the following service providers who assist us with the internal operations of the Solution: Amazon Web Services, Inc. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own purposes.
We may share your Information when you violate the terms of your engagement with FlyWeel.
If you have breached our terms of service, this Policy or any other agreement you have with FlyWeel or violated any applicable law – your Information will be shared with third parties (such as legal counsels and advisors), who handle the matter on our behalf, or with the competent authorities.
The legal basis under EU law for this processing is our legitimate interests in protecting our business.
We may share your Information if we are legally required.
If we are bound to disclose your information by a judicial order or by a governmental or regulatory authority acting within its legal authority, we will comply and share the Information. who handle the matter on our behalf, or with the competent authorities.
The legal basis under EU law for this processing is our compliance with a legal obligation.
We may share your Information if we change FlyWeel’s business structure.
If we organize the operation of our company within a different framework, or through another legal structure or entity (such as due to a merger or acquisition) – we will share your Information to enable the structural change. However, the receiving party will be bound by this Policy.
The legal basis under EU law for this processing is our legitimate interests in business continuity following the structural change.
The legal basis under EU law for these cookies is the explicit consent you provided to the Publisher.
SECURITY AND DATA RETENTION
How long will we retain your Information.
We retain your Information as long as we need it for the purposes for which it was obtained or until you ask to delete it. If you ask us to delete the Information, we may still have to retain it to comply with our legal obligations, resolve disputes and enforce our agreements.
We implement measures to secure your Information.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.
INTERNATIONAL DATA TRANSFERS
We will transfer your Information to third countries only in accordance with applicable data protection laws.
We transfer your Information from within the EU to the United States under the safeguards of EU Model Clauses.
YOUR EU RIGHTS
You have the right to access, update or delete your Information and obtain a copy of your Information.
If you are in the EU, you have the right to access the personal information about you that we store on our systems, and have us update, correct or delete it. You are also entitled to obtain from us your Information (excluding data we obtained from other sources) in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact us at firstname.lastname@example.org.
You can withdraw your consent.
If you provided your consent to have your Information processed by FlyWeel, you can withdraw your consent at any time, by contacting us at: email@example.com.
You have a right to submit a complaint to the relevant supervisory data protection authority.
If you are in the EU, you can lodge a complaint to the supervisory authority under the General data Protection Regulations (“GDPR”), in particular in the Member State of your residence, place of work or where the alleged infringement of the GDPR occurred.
We do not knowingly collect information from minors under the age of 16.
We do not knowingly collect or solicit personal information from anyone under the age of 16.
We may change the terms of this Policy.
From time to time, we may change and update the terms of this Policy. Technical changes in the Solution, new features and evolvement of relevant legal aspects, will require us to adapt this Policy.
DATA CONTROLLER AND DATA PROCESSOR
We are the data processor on behalf of the publishers, who are the data controllers.
The publisher is the data controller of your personal data collected for the purposes of personalized ads. It determines the purposes and means of processing your data.
To communicate with our Data Protection Officer, please email firstname.lastname@example.org.
If you have any questions or requests concerning your personal data or about our privacy practices and policies, you may contact our Data Protection Officer, at: email@example.com.
Last updated: June 1st, 2018