Introduction
This policy of confidentiality ("Privacy Policy") delivers specifics of our data processing procedures for our customers ("Users", "Data Subject", or "You") when You visit our websites and/or employ our services (as detailed below).
This Privacy Policy integrates into Your agreement with us when You browse our website, found at www.prommatic.cm or any subdomain or website that directs to this Policy, (the "Site" or "Website"), or while leveraging the Prommatic web platform ("Prommatic", "web platform" or "Platform") (each individually, or collectively with the Site and Product, the "Services").
Your interaction with our Platform doesn't require Personal Data submission unless You willingly opt to offer us such information. Our Platform caters to pertinent users (publishers and advertisers), and some functionalities might mandate registration and provision of specific personal data, as depicted in this Privacy Policy.
This Privacy Policy was crafted in accordance with the EU General Data Protection Regulation (GDPR). Nonetheless, depending on Your residency, different regulations may govern Your Personal Data. If You are a resident of California, we recommend referring to our notice for California residents below.
The objective of this Privacy Policy (this "Policy") is to enlighten You about the utilization of Personal Data within Prommatic and those associated with us, including data processors, sub-processors, and third-party partners. This Policy will also furnish You with details about how to manage certain data gathered about You.
We urge You to revisit this Policy periodically to stay informed about our latest privacy practices. The most recent amendments to our Policy will be indicated in the "last updated" heading.
Definitions
Pertinent Privacy Regulations refers to any relevant privacy or other legislation to the extent that it applies to our operations, which includes the California Privacy Right Act of 2020, Cal. Civ. Code §§ 1798.100 et. Seq, (CPRA) if applicable; the General Data Protection Regulation (EU) 2016/679 (GDPR); and the laws, rules, and guidelines of European Union Member States that implement or complement the GDPR, as periodically amended and to the extent applicable to our Company’s function and our Services.
- Customers – Our chief customers are Advertisers or Publishers who use the Platform to establish, modify, and sustain advertising campaigns or to market advertising spots, encompassing individuals who receive or otherwise engage with the Platform and advertisement Services users ("User(s)").
- Data Subject – The individual to whom Personal Data pertains. This could be Customers or a User.- Personal Data denotes information about a living person, implying that they can be identified (a) from that data, or (b) from that data combined with any other information which is, or may in the future, be held by the data controller, and as defined under the Pertinent Privacy Regulations.Also see Special Categories of Personal Data.
- Data Controller signifies the person, organization, public authority, agency, or other body who, alone or jointly, determines the purposes and methods of any Personal Data processing, and sets the controls required for such processing.
- Data Processor designates any individual or organization (apart from an employee of the Data Controller) who performs the processing of Personal Data on behalf of the Data Controller.
- Processing refers to any action performed upon or applied to Personal Data, manually or by automated means, encompassing its collection, organization, storage, retrieval, consultation, modification, availability, disclosure, erasure, or destruction.
- Subprocessor is any entity assigned by us or by one of our sub-processors, such as our vendors, to Process Personal Data on our behalf or on behalf of that sub-processor, excluding any employee of Prommatic or of our sub-processor or of any such appointed entity but inclusive of any contractor or affiliate of the aforementioned.
- The terms “Controller“, “Processor“, “Sub-Processor”, “Data Subject“, “Personal Data“, “Processing” (and/or “Process“), “Personal Data Breach”, the “Union”, “Member State” and “Special Categories of Personal Data” shall retain the meanings stipulated under the GDPR. The terms “Business”, “Business Purpose”, “Consumer” and “Service Provider” or “Contractor” shall retain the same definitions as in the CPRA. Where CPRA is applicable, the term “Controller” shall also signify “Business”, and “Processor” shall also denote “Service Provider”.
Data Protection Roles
Data Processor: In relation to our Platform and the Services offered to our Clients, we function as the Data Processor, as we manage specific data, as detailed below.
Data Controller: Prommatic acts as the Data Controller for Your Personal Data gathered from visitors on our website and our Client's employees and representatives.
Our contact information:Pragmatic Ltd2 Filiou Zannetou St.Address
Personal Data
Personal Data comprises information linked to an individual that permits the identification of that particular User. Via ad tags and cookies, we gather information about You. Generally, the acquired information doesn't directly identify You (e.g., by name or email address), however, the information could indirectly recognize Your device or geolocate You for delivering targeted ads. Under GDPR, some details conveyed by Cookies and Tags, including Log Data, are deemed Personal Data.
What Personal Data We Collect?
We keep certain (non-sensitive) Personal Data on You for registration, logging in the Platform, and availing our Services. Data may also be received from third parties like analytics providers (refer to 'Disclosures of Your Personal Data to Third Parties' below).
-Contact Information – We manage our Clients’ and Users’ contact information (like name, email address, or phone number) if You have submitted those to us during communication, account creation, subscription to our mailing list or while seeking our support services. This data is processed for communication and service delivery purposes.
-Sign Up & Registration Information for our Platform – Your first and last name, postal address, phone number, email address, and other similar contact details. This data is processed for operation of the Platform; communication with You; record keeping and for the establishment; pursuance or defense of legal claims.
-Data processed concerning Clients, Users, and advertising (Device and Connection Information) Details of Your IP (Internet Protocol) Address, geo-location, RTB protocols (e.g., IFA), User-Agent, and activity including accessed pages, including URLs of websites or names of applications accessed. User’s device details and the context of where it is seen, related to URLs and applications, are essential for general ad targeting advertising. These elements of a User’s browser or device are available for targeting but are not made available to target a User individually. Where ads may be targeted directly to a User – commonly called “retargeting”, in service of an advertiser or merchant whose website or app a User may have interacted with previously, clear and informed consent will be collected by the Clients before such retargeting techniques will be activated.
-Purchasing Services – To avail Services from us, You will be asked to provide Your contact information, such as Your full name, email address, billing information, and any other purchase-related information.
-Technical/Entry Information – We maintain records that include Your IP (Internet Protocol) Address, User’s activity including accessed pages, and the information entered for the purposes of fraud detection and security auditing.
-User Information: This encompasses data about how You utilize the Website and the Platform. It may incorporate connectivity, technical and aggregated usage information, IP addresses, device details (such as type, OS, device ID, browser version, locale and language settings utilized), approximate geolocation.
-Raw Information. For statistical and operational purposes, we may accumulate and process raw data from our Clients’ requests acquired during RTB auctions. When our Client avails our Services, we process only their statistical tracking details, containing non-identifiable data as provided by our Clients’ use of our Product and Services as Data Controllers (State-level geolocation only). We also process raw data from requests obtained during RTB. Nonetheless, we strive to ensure our sub-processors employ suitable technical and organizational measures to safeguard the protection and retention of Data Subjects.
-Any other Personal Data that You opt to send to us.We utilize our Users and Client's (including End Users) Personal Data for the objectives we detailed adjacent to each data type above, and for the following objectives:
-Delivering our Services and managing and operating our Platform;-to facilitate and bolster Your usage of the services accessible on our Platform;
-for business expansion and research and to test potential features or additional services;
-To supply third parties with statistical data about our users (however, these third parties will not be capable of identifying any individual user from that data);
-To provide communications, marketing, and advertising via the Client’s Platform;
-To offer reporting and analytics;-To deliver troubleshooting, support services, or respond to inquiries;
-To assist Clients with integration with third-party publishers and advertiser platforms via our Platform;Security and Fraud Prevention. To safeguard our Users and Clients and to avert fraud. To deliver troubleshooting, support services, or answer inquiries;
-Create an account for You, manage it, and provide support;
-Communicate with You and our Clients. To react to communications, reach out to our Users and Clients about their transactions or accounts, market our Products and Services, deliver other relevant information, or request information or feedback. Occasionally, We may use Your Personal Data to send crucial notices, such as communications about alterations to our terms, conditions, and policies;
-Comply with Law.To adhere to applicable law — for instance, to meet tax or reporting obligations, or to comply with a lawful governmental request and to pursue the following legitimate interests, either for ourselves, our Clients, or other third parties. If we need to do so to establish, exercise, protect or defend our contracts or legal rights, or the rights of others including our employees and affiliates, or detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, we may share Personal Data with investigators, advisors, consultants, or law enforcement authorities.-If it is in our legitimate interests, for business development and marketing purposes:-We may use Your Personal Data to offer You with marketing information about products or services which we believe would be of interest to You. These may be sent by email, a text message, or any other accessible channels, in some situations, we may call You to explain this information to You.
-We make sure that our marketing activities comply with all applicable legal requirements and relevant privacy laws. This means that we ask, and You hereby consent that we send You marketing materials.In all situations, You can opt-out of receiving marketing communications, at any time. You can do this by clicking on the “unsubscribe” link in any marketing email or by contacting us using the details set out at the end of this Privacy Policy.
Please be aware that, even if You opt-out of receiving marketing messages, we may still send You communications in relation to the services we provide to You.
The Personal Data we gather and process, as outlined above, is necessary for secure account access and for securing the data systems of the Platform. We will not sell our Clients and Your Personal Data or otherwise transmit it for commercial usage. We do not plan to process any sensitive data about You.
Your Rights As a Resident of the European Economic Area
If You are situated in the European Economic Area (“EEA”), You possess certain rights concerning Your Personal Data, including:
- the right to be informed
- the right of access
- the right to rectification
- the right to erasure
- the right to restrict processing
- the right to object to processing
- the rights in relation to automated decision making and profiling.
If You aim to revoke the consent as the User of our Platform, please contact our Client directly. If You are our Client, please contact us at: contact@prommatic.com.
Note that in exceptional cases, the data collected and processed until consent withdrawal might need to be further processed due to legal requirements of validating the safety and efficacy of the device and the obligation to report adverse events, if any.
You will not have to pay a fee to access Your Personal Data (or exercise any other rights).
However, we may charge a reasonable fee if Your request is unfounded, repetitive, or excessive or refuse to comply with Your request in these circumstances. If You wish to exercise any of the rights set out above, please email us at:privacy@prommatic.com.
We may need to request specific information from You to help us confirm Your identity and ensure Your right to access Your Personal Data (or exercise any of Your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to ask for further information concerning Your request to speed up our response. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if Your request is particularly complex or You have made several requests.
What are the Lawful Grounds for Processing Your data?
Our gathering and processing is crucial for the execution of a contract and our data handling agreements and/or addendums (Art 6 (1)(b)), including performance of our Services and operating our Platform. Furthermore, Prommatic processes personal data based on Your consent (Art 6 (1)(a)). We may also depend (under extraordinary circumstances) on legal obligations (Art 6 (1)(c)) or legitimate interest (Art 6 (1)(f)).
Data Retention
-We'll retain Your Personal Data only as long as needed to deliver You the Services, unless a more extended retention period is required or allowed by law (for example, for regulatory reasons).-If You're utilizing the Platform as an advertiser or publisher, we'll keep Your registration information in our records until You request us to erase or otherwise update this data.-Data Pertaining to Advertisements – Other Personal Data associated with Your connection, advertisements displayed or other related information that we process on behalf of our Clients may be stored in our databases for the duration of the Services unless dictated otherwise by specific legal obligations, dispute resolutions or contract enforcement. Following this period, The Company and its Vendors may preserve and utilize such data in an aggregated format, as required for internal analytical purposes, compliance with legal obligations, dispute settlements and contract enforcement.-If You revoke Your consent for us to process Your Personal Data, we will delete Your Personal Data from our systems, unless the data is needed for the Company to establish, exercise or defend against legal claims or it is essential for the delivery of the requested Services.
How do we protect your information?
We employ suitable technical and organizational measures to safeguard Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, disclosure or access, in compliance with relevant laws.
During the provision of Your Personal Data to us, Your Personal Data is likely to be transmitted over the internet and/or stored on a cloud-based server. Despite our utmost efforts to protect the Personal Data that You provide to us, the transfer of Data over the internet and storage on a cloud-based server is not entirely secure. Given that interactions with the Services occur over the internet, and as an online Platform, we cannot assure that the use of the Platform and Services or the interaction with it will be entirely free from viruses, worms, Trojans, and other malware, which are beyond our reasonable control.
Therefore, You acknowledge and agree that we cannot ensure the security of Your Personal Data transmitted to or automatically generated by the Services we provide and that any such transmission is at Your own risk. We won't be liable for any damage caused by such unauthorized access or use, as long as we adhere to acceptable information procedures and measures.
Please be aware that You are responsible for the use of personally identifiable information and Your device. For instance: to protect Your Personal Data from data incidents such as online fraud (“phishing“), avoid providing identifying information to others (e.g. via email), ensure that the contact information You provide us (including Your phone number and email address) is correct. You should take measures to prevent unauthorized access to Your device(s) by, among other things, signing off after using a shared computer, selecting a robust password that nobody else knows or can easily guess, and keeping Your Platform login and password private, using anti-virus measures, and computer security means on Your end equipment from which You browse our Website. You should ensure to update software, download only from official sites, use encryption, avoid using public computers or public WIFI networks, do not share sensitive information on social networks.If You're worried that Personal Data about You that You've provided to us has reached unauthorized third parties, please contact us immediately at: privacy@prommatic.com.
Data Breach
While we can't assure absolute protection against data misuse or unauthorized breaches, we are committed to taking all reasonable steps to prevent such events. We do not promise or claim that your account or any of your information is completely safeguarded against potential misuse by external entities.
In the event of a security breach which we ascertain may have compromised your Personal Data, we will make prompt attempts to notify you and also inform the appropriate local authorities, where necessary.
Do we disclose any information to third parties?
We may share your information under these circumstances:
-Third-Party Service Providers: We share Personal Data with trusted service providers and subcontractors, including white-label marketplace platforms, technical, IT, hosting (including cloud-based computing services), logistical, or administrative service providers, accountants, consultants, insurers, and client care service providers, as well as other outsourcing services necessary to provide our Services and operate our Website and specific functionalities, for the purposes stated in this Policy or upon your request.
-Official Authorities: We may disclose Personal Data in response to lawful requests by public authorities or law enforcement officials, or to fulfill law enforcement requirements.
-Legal Requirements: If required or authorized by law, we may share your Personal Data with third parties needing information for legal reasons or with third-party investigators, authorities, regulators, or law enforcement bodies, when necessary to comply with the law, protect or defend our legal rights, or protect the rights of others (including investigating and protecting our users from fraudulent or unlawful use of the Website or Platform).
-Affiliates: Your Personal Data may be shared with our affiliates for internal administrative purposes (e.g., corporate strategy, compliance, auditing and monitoring, research and development, and quality assurance), including with our subsidiaries, affiliated and parent companies, in line with our legitimate interests in providing the Site to you. Their use of such information must comply with this Policy.
-Analytics Providers: We share data with analytics providers that help us improve and optimize the Website and Platform and process Personal Data in the context of providing analytical services to us.
-Preventing and Addressing Misconduct: We share data to prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service, or any other agreement related to the Platform, or as otherwise required by law. We also share data to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including meeting national security or law enforcement requirements).
-Business Transfers: Personal Data may be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or a similar transaction or proceeding. If this occurs, we will post a notice on our homepage.
Direct Marketing
Should you provide us with your contact details via our Website, where it's specified that these details will be used to send you various offers related to our Services, you hereby consent to us using these contact details. This allows us to reach out to you, inform you about our products and Services that may interest you, and send you additional marketing materials, including news and updates, to the email address or phone number you have provided. You can withdraw your consent at any point in time by sending us a written notice to the following email address: privacy@prommatic.com
International Transfers
If you reside within the EEA, be aware that your data may occasionally be transferred outside the EEA, to third-party service providers such as those offering IT, hosting, and marketing services. We are, however, subject to the GDPR provisions that safeguard your Personal Data.
-When exporting Personal Data outside the EEA, we typically:
-Under Article 46.2 of the General Data Protection Regulation (GDPR), incorporate the standard contractual clauses approved by the European Commission Implementing Decision (EU) 2021/915 of 4 June 2021 (hereafter referred to as "SCC" and/or "Standard Contractual Clauses") into our contracts with such third parties for the transfer of Personal Data outside the EEA; or-Under Article 45 of the GDPR, ascertain that the country where your Personal Data will be processed (such as Israel, where our Company is headquartered) has been declared "adequate" by the European Commission.
We will ensure that certain protective measures are in place to provide a comparable level of security for your personal data. If such safeguards aren't available, we may seek your explicit consent for the specific transfer. You can withdraw this consent at any time by sending us a written notice via email to the following address: privacy@prommatic.com.
Notice to California Residents
This segment is applicable to residents of California and provides an overview of your rights and choices concerning Prommatic's handling of your data under the CPRA.Prommatic does not engage in the sale of data – We refrain from selling personal data for business or commercial objectives.
Consumer Rights
California consumers (users from the State of California) have the following rights under the CPRA in addition to other rights described in this Privacy Policy:-Right to know: You have the right to know what Personal Data we collect, share, or sell about you, including the categories of Personal Data, sources from which it was collected, business or commercial purposes for collecting, selling, or sharing Personal Data, categories of third parties with whom we share Personal Data, and specific pieces of Personal Data collected about you. You may request that we disclose the categories of personal information we collected, shared, sold, or disclosed in the past 12 months.-Right to delete: You may request that we delete your Personal Data at any time through your account within the Applications. Please note that we may be required by applicable law to retain certain information, such as transaction data.-Right to correct: You may request that we correct any inaccurate Personal Data that we maintain about you.-Right to opt-out of the sale: We do not sell, rent, or disclose Personal Data to third parties for their direct marketing purposes. We will only disclose Personal Data to third-party marketers upon your request.-Right to non-discrimination: We will not discriminate against you if you decide to exercise any of the above rights.
Excercising Your Rights:
To exercise any of the CPRA rights above, please contact us by sending an email to privacy@prommatic.com. We will respond to Your request within 45 days of receiving it. To verify Your request, we will use Your email address. If You have an account with us, we will also verify Your request using the information associated with Your account, including billing information.
Please note that we cannot respond to Your request if we cannot verify Your identity or confirm the Personal Data related to You. Creating an account is not necessary to make a verifiable consumer request. If You wish to use an authorized agent to submit a request to opt-out on Your behalf, You must provide the agent with written permission signed by You, the consumer. We may deny a request from an authorized agent if they cannot provide Your signed authorization demonstrating that they have been authorized to act on Your behalf.
A Children’s’ Online Privacy Protection Act Compliance (COPPA) Notice
The Platform and Services are designed for a general audience and are not targeted towards children under the age of 13. We do not intentionally collect Personal Data from children under the age of 13. If You become aware that a child has provided us with Personal Data without parental consent, please contact us at: privacy@prommatic.com.
If we discover that a child under 13 has provided us with Personal Data without parental consent, we will take steps to remove such information and terminate any account linked to such underage minor.
Cookies
We, along with our third-party partners, may utilize Cookies, including web beacons, tags, scripts, and advertising identifiers, in association with Your use of the Platform, third-party websites, and mobile applications. Cookies may contain unique identifiers and may be present on Your computer, mobile device, in emails we send to You, or on our web pages. Cookies may transmit information regarding Your use of the Platform, such as Your search preferences, browser type, IP address, data related to ads displayed or clicked, and the time and date of use. Cookies may persist or be stored only for a single session.
Necessary Cookies
The functionality of a website relies on necessary cookies which allow for basic functions such as accessing secure areas and navigating through pages. Without these cookies, the website will not be able to operate correctly.
Elementor (Provide: Pragmatic), Expiry: persistent, Purpose: This cookie is used in conjunction with the website's WordPress theme, enabling the website owner to make real-time content changes or implementations.
rc::a (Provider: Google.com), Expiry: persistent, Purpose: This cookie serves to differentiate between human users and bots, which helps the website generate accurate usage reports.
Rc::c (Provider: Google.com), Expiry: Session, Purpose: This cookie helps differentiate between human users and bots.
We partner with the following third-party providers, and you can review their privacy policies to learn more about their privacy practices:
-WordPress -https://wordpress.org/about/privacy/cookies/While you can adjust your Cookie preferences through your device or browser settings, please note that this may impact the functionality of the Platform. The process for disabling Cookies may vary by device and browser, but is typically available in your device or browser preferences or security settings. Please be aware that modifying these settings does not necessarily prevent certain advertisements from being displayed to you.
Changes to the Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in our practices or for operational, legal or regulatory reasons. The latest version of our Privacy Policy will apply to the collection, use, and disclosure of information about You. Your continued use of our services after any modifications to the Privacy Policy are effective will constitute Your acknowledgment of the updated Privacy Policy.
How to Contact Us
If you have any inquiries regarding this Privacy Policy, please don't hesitate to contact us via email or mail at the address provided below: privacy@prommatic.com. prommatic.com
