Privacy Policy

Effective date: May 9, 2023

1. OVERVIEW

Please review this Privacy Policy carefully as it describes how internetoglasnik.com (“Internet Oglasnik”) and its affiliates and subsidiaries, including other affiliated websites, the “Company”, “we”, “our”, or “us”) collect, use, and disclose information about you as well as your rights and choices about such use and disclosure. It applies to our websites under the Internet Oglasnik brand or under the company AndromedaG (the “Websites”), our mobile applications that post a link to this Privacy Policy and any other online services owned, controlled or offered by us that post a link to this Privacy Policy (collectively, the “Service”).

If you have any questions about our privacy practices, please contact us as set forth in the “Contact Us” section below.

2. INFORMATION COLLECTION

For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through the Service will be apparent by the context of the page and/or the circumstances in which the personal information is being collected. This may include collection and processing of personal information including, but not limited to, the categories and types of personal information listed below.

INFORMATION YOU PROVIDE

We collect personal information you provide directly via the Service, including when you:

Use our Service, including our Websites and Apps;
Access our content, including our articles, webinars, research reports and podcasts;
Register or update an account;
Request quotes, product demos, support, information, or access to our information products and services;
Subscribe to newsletters, promotional communications, alerts, sales outreach, updates and other materials;
Fill in forms, including when you enter competitions, promotions or surveys;
Register for events, webinars or other content offers; or
Contact us.

The categories of personal information we collect include the following:

Contact Data. We may collect your first and last name, email address, postal address, phone number, and similar contact data.
Company Data. Where you interact with us in a business to business context, we may collect your job title and company name, size, email address, phone number, and postal address.
Credentials. When you register for an account with us, we may collect passwords, password hints, and related information for authentication and account access.
Demographic Data. We may collect demographic information including your country.
Profile Data. We may collect a personal description, photograph, and other profile information you submit.
Payment Data. We use payment processors to collect personal information necessary to process your payment if you make a purchase with us, including your payment instrument number (such as a credit or debit card number), and the security code associated with your payment instrument. The Company itself does not directly collect or maintain full payment card information.
Personal Contacts Data. We may collect personal information you provide about your contacts, including information about other employees at your company.
Content. We collect the content of communications you send to us (such as feedback and questions to customer support), which may include personal information.

You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.

INFORMATION WE AUTOMATICALLY COLLECT

When you access the Service via a web browser, mobile application, newsletter, or other client, we and other parties use a variety of technologies, that automatically collect information about your device and how your device interacts with our Service, which may include personal information. The categories of information we automatically collect include the following:

Service Use Data. We collect data about your interaction with our Service, the webpage, newsletter, or services feature you were using before you came to our Service, your web or application request, pages of our websites that you visit, information you search for via our Service, access times and dates, and other similar information.
Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other unique identifiers for the particular device you use to access the internet.
Location Data. We collect data about your device’s location, which can be precise with your consent (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).

We use this information for a variety of purposes (further addressed in “Our Use of Your Information” below), including analyzing and enhancing our products and services, personalizing our Service for you, and serving advertising.

We and other parties automatically collect this information using various methods, including the following:

Log Files. Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
Cookies. A cookie is a small data file transferred to your computer (or other device) when it is used to access our Service. Cookies may be used for many purposes, including to enable certain features of our Service and remember your preferences, to better understand how you interact with our Service, to provide you advertising on and off the Service, and to monitor usage by visitors and online traffic routing. You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. By clicking “accept”, closing the message, or continuing to browse the Websites, you signify that you understand and agree to the use of these technologies. You do not have to accept cookies and consent can be withdrawn at any time, however, you may not be able to use all portions of our Service or all functionality of our Service.
Web Beacons (“Tracking Pixels”). Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons are used in combination with cookies for various purposes, including to allow us to count the number of visitors to the Service, to monitor how users navigate the Service, to count content views, and to provide you advertising.
Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Service and deleted or deactivated thereafter.
Click–Through URLs. In some of our e-mail communications, we use a “click-through URL” linked to content on our websites. When users click one of these URLs, they pass through a separate web server before arriving at the destination page on our Websites. We track this click-through data for various purposes, including to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the e-mail messages.
Location–identifying Technologies. GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
Device Fingerprinting. Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and applications.
App Technologies. Our Apps include technologies that are not browser-based and cannot be controlled by browser settings. Information may be sent to us and other parties when you install or uninstall mobile applications or when such Apps periodically contact our and other party servers. For example, our apps may include SDKs, which is code that sends information about your use to a server, for instance through the Facebook SDK. These SDKs allow us to track our conversions, bring you advertising, and provide you with additional functionality.

For further information on how we use tracking technologies for analytics and advertising and your rights and choices regarding them, please see the “Analytics and Advertising Technology” and “Your Rights and Choices” sections below.

INFORMATION FROM OTHER SOURCES

We also obtain personal information about you from other sources. To the extent we combine such sourced information with information we have collected about you on the Service, we will treat the combined personal information in accordance with the practices described under this Privacy Policy, plus any additional restrictions imposed by the source of the data. These sources have included or may include:

Data brokers from which we purchase demographic data and other personal information to supplement the personal information we collect.
Social networks when you reference our Service or grant permission to Internet Oglasnik to access your personal information on one or more of these services.
Our clients or other partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
Analytics and advertising partners such as advertising exchanges, advertising servers, data management platforms, content recommendation platforms and analytics providers provide information to use about your interaction with our Service or our content on or off our Service.
Publicly-available sources such as open government databases or other personal information in the public domain.

We are not responsible for the accuracy of any information provided by other parties or for their policies or practices.

3. USE OF YOUR INFORMATION

We collect and use information for our legitimate interests, including business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

To operate and manage our Service, including your registration and accounts on our Websites;
To provide the products and services you request and purchase, allow you to participate in panels, events, sweepstakes and contests, and carry out the transactions you have requested;
To provide you with customer support and respond to your questions;
To communicate with you regarding updates, technical notices, orders, security alerts, administrative messages, and information regarding changes to our policies;
To help authenticate any account you create with us;
To comply with legal obligations, protect the rights or property of AndromedaG or Internet Oglasnik, our users, or other parties, and prevent fraud and other prohibited or illegal activities;
To protect the security of our products, services, and business;
To enhance and personalize our Service, products and our marketing efforts;
To develop and serve advertisements on our Service or through e-mails or other communications; and
For our internal purposes (such as auditing, bug detection and error reporting, data analysis, and research to improve our products, services, content, advertising, and communications and develop new ones).

We also use your information with your consent, including:

To administer promotions you have entered; and
Fulfill any other purpose disclosed to you and with your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

We share your personal information as described in this Privacy Policy. The types of entities to whom we disclose personal information with include the following:

Our Service Providers

We engage companies and individuals to perform services on our behalf (e.g., software maintenance services, cloud storage, order fulfillment, advertising serving technologies, e-mail services, delivery services, database management, web analytics, credit referencing, payment processing and other services). These service providers have access to your personal information so that they may perform these tasks on our behalf and they are prohibited by us from using or disclosing your information for any purpose other than to provide this assistance, except to the extent required by law. We may permit our service providers to use aggregate information which does not identify you or de-identified data for other purposes, consistent with applicable law.

Affiliates

We share your personal information with our affiliates, related entities, and holding companies for our and their business and commercial purposes, including for customer support, marketing, and technical operations.

Clients

We share your personal information with our clients in connection with us processing your personal information on their behalf. For example, if you subscribe to our newsletters and promotional communications, AndromedaG or Internet Oglasnik may send you content on behalf of their clients and share your personal information with such clients for their own marketing purposes.

Business Partners

We share your personal information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. In addition, if you choose to participate in certain of our programs or to receive certain content we make available (e.g., webinar programs), we may share your information with participating sponsors, content providers, and related vendors in connection with such programs and content.

Sponsors

We may share your email address with sponsors where we get your opt-in consent for an event.

Facilitating Requests

We share your personal information to facilitate your requests such as when you choose to share information with a social network about your activities on the Service or participate in a business partner’s program.

Vendors and Other Parties

We share personal information with vendors and other parties, for business and commercial purposes, including analytics and advertising technology companies that measure and improve our Service, advertising effectiveness and enable other enhancements. Vendors or such other parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on practices related to advertising and analytics, see the “Analytics and Advertising Technology” section below.

Compliance with Laws, Legal Process and Authorities

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We must disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. We may also disclose information to protect the rights, property, life, health, security and safety of us, the Service or any third party.

Business Transfers

Circumstances may arise where, whether for strategic or other business reasons, we may sell, transfer or otherwise disclose some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Consent and Disclosure

We share your personal information for purposes disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

5. OTHER PARTIES

Our Service contains links to, or content from, other party’s websites and other products and services. The fact that we link to a website or display an advertisement or other party’s content is not an endorsement, authorization or representation of our affiliation with any of those other parties, nor is it an endorsement of their privacy or information security policies or practices.

We do not exercise control over other parties’ websites, products or services, and whether they store information in the U.S. or elsewhere. These other products and services may place their own cookies or other technologies on your computer or other device, collect data, or solicit information from you. Other persons and entities follow different rules regarding the use or disclosure of the information you submit to them or they collect from you. We encourage you to learn about the privacy practices of those other parties.

Blogs, Social Media and other Public Forums

We may offer blogs, social media profiles, message boards, bulletin boards or similar public forums where you and other users of our Service can post content or otherwise communicate. If you post personal information on a public forum, we will assume you intend to make that personal information public. We may use your name to identify you with a posting in a public forum and may use your post on or in connection with our Service (e.g., when using a hashtag associated with Internet Oglasnik in a tweet or status update). Any personal information you share in a public forum is public information and may be seen or collected by other persons, including third parties that do not adhere to the standards set forth in this Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our online services.

In addition, to the extent you interact with social networks or other services through the Service (such as “liking” or “sharing” our content or otherwise connecting our Service to a social network), understand that information collected and stored by those other parties through your interaction or pages that contain their tracking technologies remains subject to their policies and practices, including whether they share information about you with us, the types of information shared, and your choices on what is visible to others. We are not responsible for and make no representations regarding the policies or business practices of any other parties or their services and encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Analytics and Advertising Technology

Our Service contains tracking technologies owned and operated by other parties. For example, we use tracking technologies from analytics services, such as Google Analytics, to help us understand how users access and use the Service.

We also work with ad networks, advertisers, agencies, and other technology services to place advertisements on the Service and/or other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services. These parties may set and access cookies and other technologies on your personal computer and/or device and track certain behavioral information regarding users of your personal computer and/or device. These cookies and other technologies are set to, among other things: (a) track your activities across time and services for purposes of measuring conversions or actions you take, associating different devices you use, and serving ads and/or other content targeted to your interests (“Interest-based Advertising”); (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you.

We also use audience matching services (which is a type of Interest-Based Advertising) to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). This is done by us sharing a list of hashed emails with an ad partner or incorporating a pixel or SDK from an ad partner into our own Services, and the ad partner matching common factors between our data and their data or other datasets. For instance, we use Facebook Custom Audiences to serve ads to our customers on Facebook and Facebook Lookalike Audiences to serve ads to users on Facebook similar to our customers.

As discussed above, vendors and ad partners may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use. For further information on your choices regarding these third party tracking technologies, please see the sections entitled “Information We Automatically Collect” above and “Your Rights and Choices” below.

7. YOUR RIGHTS AND CHOICES

Accounts

Depending on the account, you may be able to access information that you have voluntarily provided to AndromedaG or Internet Oglasnik through your account on the Service, and to review, correct, or delete it by following the instructions on the Service. For example, if you have a subscriber account there are additional functions available within your account settings to exercise your rights and choices concerning the information you provide. Meanwhile, other accounts may not have the same functionality.

Alternatively, if your account does not offer the functionality to edit the information in your account settings, you can contact Internet Oglasnik in writing as set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note we will retain and use your data, including server/backup copies, to comply with our legal obligations, resolve disputes, and enforce our agreements, and we may decline to process change or deletion requests that require disproportionate technical effort or jeopardize the privacy of others.

Tracking Technologies Generally

Cookies and location-identifying technologies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. You can stop all collection of information via our mobile application by uninstalling it. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. Please be aware that if you disable or remove these technologies some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.

Do Not Track

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Analytics and Advertising Tracking Technologies

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

Some of the advertisers and vendors that perform advertising-related services for us and our partners participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile applications. Some of these companies are also members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.

To opt out of us sharing your hashed email address for Matched Ads, please contact us and specify that you wish to opt out of Matched Ads. We will remove your email address from any subsequent lists shared with ad partners for purposes of Matched Ads.

Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Internet Oglasnik 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.

Communications

If you decide at any time that you no longer wish to receive newsletters or promotional communications from us, please follow any unsubscribe instructions provided in our communications to you, update your user preferences via our subscription management tools on our Service, or contact us as set forth in the section below entitled “Contact Us” and specify your request. Please note that you cannot opt out of non-promotional e-mails, and we may use your information to contact you with important notifications, such as notices with respect to purchases, safety, or changes to our terms, conditions, and policies. Also, your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions.

Other Rights Specific to Your Location

Residents of certain jurisdictions, including Nevada, California, Virginia, the European Economic Area, and the United Kingdom, have specific rights with respect to our collection, use, and sharing of personal information. Please review our location-specific sections below for more information about those rights.

8. SECURITY AND DATA RETENTION

We employ appropriate security measures designed to protect your information from unauthorized access, alteration, disclosure, or destruction. Please be advised, however, that while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your information.

If you suspect unauthorized use of personal information that you have provided us – such as your account information or its credentials – you should notify us immediately using the information in the Contact Us section at the end of this Privacy Policy.

9. INTERNATIONAL TRANSFER

Your personal information may be transferred to, and used, in locations outside of USA, your state, province or other governmental jurisdiction where the privacy laws may be different than those in your jurisdiction. Your use of the Service or provision of any personal information constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in North Macedonia and other jurisdictions as set forth in this Privacy Policy.

To the extent that the Company offers products and services to individuals located in the European Economic Area or United Kingdom, or to the extent the Service is intentionally available to such individuals, please review the section titled “Additional Disclosures for Data Subjects in Europe” below for more information about disclosures and privacy rights associated with that activity.

10. OUR POLICY TOWARD CHILDREN

We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) from children under 13. We encourage parents and guardians to take an active role in their children’s online activities and interests. If you are a parent or guardian and believe we have collected information in a manner not permitted by COPPA, please contact us and we will remove such information to the extent required by COPPA.

11. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time. If we make changes, we will revise this Privacy Policy to reflect such changes and revise the effective date included at the beginning of this policy. We may provide you additional notice (such as to your e-mail address) if the changes are material. Your use of the Service following any such notice will signify and constitute your assent to and acceptance of such revised Privacy Policy.

12. CONTACT US

If you have any questions about this Privacy Policy, including our compliance with applicable law, please feel free to contact Internet Oglasnik directly:

By e-mail at [email protected]

13. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

These additional disclosures apply only to individuals who are California residents. The California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020 (“CCPA”) provides additional rights to know, delete, correct, limit, and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA.

For the purposes of this Section 13, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular resident or household. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified or aggregated; or other information covered by certain sector-specific privacy laws, as consistent with state law. Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy .

a. Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

Identifiers, including name, email address, phone number, address, account name and password (and other information used for authentication purposes), IP address, ID or number assigned to your account or device.
Personal information described in California Civil Code § 1798.80(e), including name, phone number, address, physical characteristics or description, and billing and shipping address and credit or debit card information, to the extent collected by our payment processors on our behalf as necessary to process payments with us.
Characteristics protected under California or federal law, such as your age, gender, country of origin or residence, and other information you may provide in connection with your profile on our Service.
Commercial information, including our Services that you have purchased, obtained, or considered; and/or other purchasing or consumer histories, tendencies, and preferences..
Internet or other electronic network activity information, including your interactions with our Service and other information disclosed in Sections 2 and 6 of this Privacy Policy.
Geolocation data, including location enabled services such as WiFi and GPS.
Audio, electronic, visual, thermal, olfactory, or similar information, which includes photographic images; and call and voicemail recordings.
Professional and employment-related information, such as your job title and company name, size, email address, phone number, postal address, and related information regarding employees and other representatives of our enterprise clients.
Inferences, including information about your interests, preferences and favorites.

Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.

Sensitive personal information. Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” as defined by California law, including:

Account log-in number combined with required security or access codes, passwords, or other credentials allowing access to an account; and
Precise geolocation.

b. Sources of Collected Personal Information

For more information on the sources from which we have collected personal information in the past 12 months, review the “Information Collection” section above.

c. What We Do With Your Personal Information

We collect and use these categories of personal information for the business purposes described in the “Use of Your Information” section, including to operate and manage our Services.

The types of sensitive personal information that we collect as described in Section 13(a) above may be used for the following purposes:

CATEGORY OF SENSITIVE PERSONAL INFORMATION

PURPOSE(S)

Account log-in number combined with required security or access codes, passwords, or other credentials allowing access to an account

To operate and manage our Service, including your registration and accounts on our Websites; to help authenticate any account you create with us

Precise geolocation

To operate and manage our Service, including your registration and accounts on our Websites; to provide the products and services you request and purchase, allow you to participate in panels, events, sweepstakes and contests, and carry out the transactions you have requested; to enhance and personalize our Service, products and our marketing efforts; to develop and serve advertisements on our Service or through e-mails or other communications; for our internal purposes (such as auditing, bug detection and error reporting, data analysis, and research to improve our products, services, content, advertising, and communications and develop new ones)

We will retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether you have provided, and the nature of, your directions and/or consent to us or others; (iii) whether there is a legal obligation to which we are subject; (iv) whether there is a privacy right for which the personal information has been exercised (such as a request to delete); and (v) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

d. Who We Disclose Personal Information To

We disclose the categories of personal information to the categories of service providers and third parties identified in Section 4 above, and in the ways described in that section.

This includes disclosure of your personal information to service providers for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 13(a), including the listed sensitive personal information, for one or more of the business purposes detailed in this Privacy Policy.

The Company “sells/shares” personal information as defined by the CCPA to the extent the Company engages third parties to use tracking technologies on its Services, including for cross-context behavioral advertising and other purposes detailed in Sections 2, 4, and 6 of this Privacy Policy. Specifically, as with many online companies, Internet Oglasnik partners with third parties to show you personalized ads on behalf of advertisers and to manage our marketing on other platforms, where such advertising is based on your past visits to our Service, as well as certain analytics. These third party partners may use tracking technologies, such as cookies, to gather information about your activities on the Service, or on other platforms, to deliver such advertising to you when you visit our Services or other third party platforms. For instance, advertisers may provide us with certain information that enables us to show personalized advertisements to you on our Services on behalf of those advertisers. As another example, if you visit our Websites, a cookie may be attached to your browser that allows us to deliver advertising to you on other third party platforms. Please also review our disclosures in Sections 2 and 6 of this Privacy Policy.

The Company also “sells/shares” personal information with third parties to facilitate other advertising to you by us and others, such as for data enrichment, audience matching, and analytics services.

In the last twelve (12) months, we have ”sold”/“shared” the following categories of personal information to third parties, including to advertising and marketing partners and data analytics providers:

Identifiers
Characteristics protected under California or federal law
Commercial information
Internet or other electronic network activity information
Geolocation data, including precise geolocation
Inferences

Please review the “Information Sharing and Disclosure” section for more detail about the parties with whom we have shared personal information in the past 12 months.

e. Your Privacy Rights

The CCPA provides California residents with specific privacy rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

If you are a California resident, you have the right to make the following requests under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, and to whom, as applicable. You may request either a report disclosing the general categories of the personal information we collect, or a report disclosing the specific pieces of personal information we collect.
Right to Delete. You have the right to request, under certain circumstances, the deletion of your personal information that we collect.
Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the “sale” or “sharing” of your personal information, as those terms are defined under California law. As disclosed in Section 13(d) above, the Company “sells/shares” your personal information with third parties for cross-context behavioral advertising and certain analytics. Please review our “Notice of Right to Opt-Out” below for more information about how to exercise this right.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our Products and Services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Correct. You have the right to request the correction of your inaccurate personal information.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

How to submit a request. To exercise any of these rights, please submit a request in one of the following ways:

For Internet Oglasnik, please email us at [email protected] with details of your request.

We will confirm receipt of your request within 10 business days. We may require, or provide you with the opportunity to provide, additional information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

If personal information about you has been processed by us as a service provider on behalf of a client and you wish to exercise any rights you have with such personal information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal information. We will refer your request to that client and will support them to the extent required by applicable law in responding to your request.

Requests by authorized agents. You may designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. If you should use an authorized agent to exercise your various rights under the CCPA, we require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. If your authorized agent does not submit proof that they have been authorized by you to submit verified requests for disclosure and deletion, we reserve the right to deny such a request that we have received and will explain to your authorized agent why we have denied such request.

f. Notice of Right to Opt-Out

As described in Section 13(d) above, the Company “sells/shares” personal information as defined by the CCPA . You may opt-out of the sale/sharing of your personal information at any time by emailing Internet Oglasnik at [email protected].

g. Notice of Financial Incentives

We may offer incentives on products or services, such as discounts or exclusive offers, by enrolling in newsletters or other programs. If and when we offer such programs, we will ask for certain of your personal information in order to become eligible for the incentives. The programs that may potentially be available to you are:

Internet Oglasnik Newsletter. If you sign up for our Internet Oglasnik Newsletter, you will receive exclusive deals and independent product reviews. In order to participate, you need to visit Internet Oglasnik’s “Newsletters” page accessible here and provide your email address.

h. Shine the Light

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” section above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

14. ADDITIONAL DISCLOSURES FOR VIRGINIA RESIDENTS

These additional disclosures apply only to individuals who are Virginia residents. The Virginia Consumer Data Protection Act (“VCDPA”) provides additional rights and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

For the purposes of this section, except where a different definition is noted, “personal information” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal information does not include de-identified data or publicly available information. For purposes of this section, publicly available information means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience

a. What Information We Collect

We may collect the personal information from or about you as detailed in Sections 2 and 13(a) of this Privacy Policy. Certain of the personal information described above constitutes “sensitive personal data” as defined under Virginia law:

Precise geolocation data

b. What We Do With Your Information

We may collect or use personal information from you for the purposes identified in Sections 3 and 13(c) of this Privacy Policy. To the extent we collect sensitive personal information as identified in Section 14(a) above, it may be used for all of these purposes.

c. Who We Share Information With

We may share any of the categories of personal information identified above with our service providers receiving information to perform services for us on our behalf.

We do not “sell” your personal information as that term is defined under Virginia law, which is limited to the exchange of personal information to a third party for monetary consideration.

As detailed elsewhere in this Privacy Policy, we do share personal information that is gathered when you visit our Service, such as cookies and pixels, with third parties for targeted advertising purposes. You may opt-out of such sharing by following the instructions provided in Section 14(d) below.

d. Your Privacy Rights

If you are a Virginia resident, you have the following rights under Virginia law with respect to your personal information:

Right to Access. You have the right to request what personal information we collect, which may include requests to obtain a copy of such information in a portable and readily usable format, in certain circumstances.
Right to Correct. You have the right to request the correction of any of your personal information that you believe to be inaccurate.
Right to Delete. You have the right to request the deletion of your personal information that is collected and maintained by us.
Right to Opt-Out. You have the right to opt-out of our processing of your personal information for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws. We will verify your identity by using data you provide, such as first name, last name, and email address. These data elements will be compared against our records for verification.

If you are a Virginia resident and wish to exercise these rights, please reach us in one of the following ways:

For Internet Oglasnik, email at [email protected].

15. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE AND UNITED KINGDOM

Data Controller

This section applies to any individuals located within the European Economic Area (EEA), United Kingdom (UK), Switzerland, or any jurisdiction to which similar privacy laws apply, from whom we may have collected personal data from any source, including through your use of our Services. We provide this Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states. Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.

For the purposes of this Notice, “personal data” means any information relating to an identified or identifiable natural person.

EU and UK data protection law makes a distinction between organizations that process personal data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). Internet Oglasnik may act as either a data controller or a data processor in respect of your personal data, depending on the circumstances. We generally act as data controller with respect to information you provide through the Service. Sometimes we operate as a data processor on behalf of a client, a separate legal entity, which is the data controller. For example, if you subscribe to our newsletters and promotional communications, we may send you content on behalf of our clients and share your personal data with our clients for their own marketing purposes. Please visit the applicable client’s privacy policy for information about their privacy practices. Any questions that you may have relating to such personal data and your rights under data protection law should therefore be directed to the client as the data controller, not to Internet Oglasnik.

Basis for Processing Your Personal Data

We rely on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our terms of use; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.

Legitimate business interests. We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.

While our legitimate interests are most extensively detailed in Section 3 of this Privacy Policy, they generally include:

Provide, improve, and develop our Websites, Apps, and Services, including to deliver your requested Services, send you messages and provide user support, customize the Services to better fit your needs as a user, develop new Services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
Protect you and others and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions on various Sites, content you submit to the Sites, and information obtained from third parties.
Provide, personalize, measure and improve our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.

Your Privacy Rights

If you are a data subject in a jurisdiction identified in this section, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, please contact us as at [email protected] and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Further, if we are processing your information on behalf of one of our clients, we will refer you to that client, and will support them to the extent required by applicable law in responding to your request. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance or you believe that we have not complied with our obligations under this Privacy Policy or European or UK law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

Data Retention

We will only retain your information for as long as necessary to fulfill the purposes we collected it for. We will retain and use your information as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. In line with this Privacy Policy, we will either securely delete or anonymize your data so that it cannot be linked back to you.

Data Transfer

We will not transfer personal data originating from the EU to third parties located outside of the EU without ensuring adequate protection under European or UK law. Where transfer is to a party located in a third country not recognized by the EU Commission as ensuring an adequate level of protection, we will take appropriate steps to transfer the personal data subject to adequate safeguards, such as standard contractual clauses as well as other appropriate measures and safeguards.