This Policy describes our online and offline information practices, the kinds of information we may collect, how we intend to use that information, with whom your information may be shared, and how you can opt-out of such uses or correct or change such information. By using our Services or our Website, you agree to the practices described in this Policy. This Policy is an integral part of and is incorporated by reference into our Terms of Service (the “Terms”). Any capitalized terms used but not defined in this Policy will have the meaning defined in the Terms.
This Policy applies to any information relating to an identified or identifiable natural person (“Personal Information”) that is collected, recorded, stored, adapted, used, or otherwise made available (collectively, “Processed”) by Eleyus in the course of our business providing an ad mediation platform, tools and other services (the “Services”) or the functionality of the Website. All individuals and entities whose responsibilities include Processing Personal Information on our behalf are expected to protect that data by adherence to this Policy. This Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.
3. Transparency/Notice: Types of Personal Information We Collect And How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Eleyus and the requirements of applicable law. Eleyus may collect Personal Information in the following ways:
- You may provide Personal Information directly to Eleyus through interacting with the Services or our Website, participating in surveys, during events, and requesting products, Services, or information.
- As you interact with the Services or our Website, certain passive information may also be collected about your visit, including through Technologies as described below. We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
(a) Types Of Personal Information Eleyus Collects
Eleyus collects Personal Information regarding its current, prospective, and former clients, customers, publishers, demand partners, users, visitors, guests, and Employees (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Services or the Website or engage in certain activities, such as registering for an account with Eleyus, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Communications with Us. We may also collect Personal Information from you such as your name, email address, phone number or mailing address when you choose to request information about our products and Services, register for a newsletter, contact customer service, or otherwise communicate with us.
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Website and/or Services and in any manner consistent with the policies provided herein.
- Automatic Data Collection. We may collect certain information automatically through our Services, Website, or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your Device when you access the Internet, location data, browser type, operating system, Internet service provider, pages that you visit before and after using the Website or our Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view on our Website, and other actions taken through use of the Website or Services such as preferences.
- Information from Other Sources. We may also obtain information about you through Third-Party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to Eleyus and to enhance our ability to provide you with information about our business, products, and Services.
(b) Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are bits of data stored on your Device through your browser or mobile application that allow the mobile application to remember you the next time you visit. Cookies enable smoother, more efficient use of the Website by storing your specific information and preferences such as theme, language setting, privacy preferences, and even user ID and password, so you do not need to reenter those each time you visit the Website. You may choose to block or delete cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website.
- Advertising Identifiers. We may also use mobile advertising identifiers to recognize your device and perform the services. Depending on your device, you can chose to change or limit the transmission of your mobile advertising identifier by going into your device settings.
- Web Bugs/Pixel Tags/Web Beacons. We may also use web bugs (also called web beacons) to help us understand the behavior of our users by allowing us to track user demographics and traffic patterns.
- Analytics. We may also utilize Google Analytics and Yandex Metrics in the collection, compilation and analysis of information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout You can out opt of Yandex Metrics by going to https://yandex.com/support/metrica/general/opt-out.xml
Our uses of such Technologies fall into the following general categories:
- Operationally Necessary. We may use Technologies that are necessary to the operation of our Services or Website. This includes Technologies that allow you access to our Services; or that are required to identify irregular Website behavior, prevent fraudulent activity and improve security;
- Performance Related. We may use Technologies to assess the performance of our Services or Website, including as part of our analytics practices, to help us understand how our visitors use our Website, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Services or Website;
- Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services or Website. This may include identifying you when you sign into our Website or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Website;
- Advertising or Targeting Related. We may use first-party or Third-Party Technologies to deliver content, including ads that may be relevant to your interests, on our Website or on Third-Party websites. This includes using Technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.
We may also combine the information we collect through Technologies with other Personal Information we have collected from and about you. If you would like to opt out of the Technologies we employ through our Services, you may do so by blocking, deleting, or disabling them as your browser or Device permits.
(c) How Eleyus Uses Your Information
We acquire, hold, use, and Process Personal Information based on the legal grounds and for the legitimate business purposes outlined in this Policy, such as:
- To Provide Services or Information Requested: Eleyus may use information about you to fulfill requests for Services or information, including information about potential or future Services, including to:
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of Eleyus’s Services or Website;
- Allow you to register for events.
- Administrative Purposes: Eleyus may use Personal Information about you for its administrative purposes, including to:
- Ensure you have a personalized and consistent experience in using the Website and Services;
- Protect the security of our Service and Websiteand to prevent fraud;
- Measure interest in Eleyus’s Services b and perform analytics;
- Notify you of changes to the Website or Services;
- Develop new Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about Individual accounts and activities on Eleyus’s Services, Website and systems, and, in Eleyus’s discretion, changes to any Eleyus policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Prevent potentially prohibited or illegal activities;
- Marketing Eleyus Services: Eleyus may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Eleyus may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information;
- Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
- Research and Development: Eleyus may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us improve our Website, to optimally deliver our existing Services or develop new Services. From time to time, Eleyus may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the Services we provide. The survey responses may be utilized to determine the effectiveness of our Services or our Website, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Anonymous and Aggregated Information: Eleyus may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the Device from which you access Eleyus’s Services or Website, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services or Website. Anonymized or aggregated information is not Personal Information, and Eleyus may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Eleyus and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Sharing Content with Friends or Colleagues: Eleyus’s Services may offer various tools and functionality. For example, Eleyus may provide functionality on its Services that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Eleyus or any other Third Parties for any other purpose.
- Other Uses: Eleyus may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
(d) Third-Party Websites and Social Media Platforms
The Website may contain links to other websites and other websites may reference or link to our Website or other Services. These other domains and websites are not controlled by us, and Eleyus does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Website and our Services may also contains links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your Device when using our Website or Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
4. Choice/Modalities to Opt-Out
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Eleyus’s Processing of your Personal Information or sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by following the instructions in this Section. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Website and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.