Privacy Policy

Last update – 29. June 2018

Marketcom Technology Limited and its subsidiaries (referred to as “Glispa”, “we”, “our” or  “us”) is a provider of digital advertising technology.

This privacy policy explains how we may use any personal information we hold in relation to you (the “user”). Publishers and advertisers with whom Glispa has a commercial relationship are referred to as “Glispa Customers” in this policy. We collect personal information in the following four ways:

  • We offer publishers of apps and websites the ability to sell their advertising space. These publishers will collect information directly from your device and disclose it to us (we refer to this as “Glispa Perform” in this policy).
  • We offer software to publishers that they can integrate into their apps (the “Glispa SDK”). Through this software we will collect information directly from your device for the purpose of serving adverts (we refer to this as “Glispa Connect” in this policy).
  • We offer an advertising platform to mobile network advertisers through which facilitates the display of adverts, videos, push notifications and smart folders (we refer to this as “Glispa Discover” in this policy).
  • We operate a self-service platform for the creation of advert formats (we refer to this as “Glispa Create” in this policy).
  • Advertisers may provide us with information about you and your device so that we can target you with specific adverts on their behalf (we refer to this as “Glispa Retargeting” in this policy).
  • We will collect information about you when you visit our website www.glispa.com, register with us or communicate directly with us.

For the purposes of applicable data protection laws, including the EU General Data Protection Regulation, as amended and supplemented (the “Data Protection Laws”), Glispa is a “controller” of personal information. If you have any questions relating to this privacy policy or our use of personal information, please contact us using the information in Section 13 below.

Glispa Connect and Glispa Discover

If you install and use an app that has integrated the Glispa Connect SDK, we will collect limited amounts of personal information about you, including:

  • Device information such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser, applications using Glispa Connect and the version of such applications, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or internal device identifier.

 

  • Information about your online activity including which adverts you viewed or clicked on and whether you visited the advertiser’s website or purchased the product or service advertised.

 

  • Log information, including the app used or website visited, session start/stop time, time zone, language, and network connection type. The geolocation of your device (using GPS or other data), when location services have been enabled for the mobile app or website that uses Glispa Connect.

 

If Glispa Discover software has been pre-installed on your device, we will collect limited amounts of personal information about you, including:

  • Device information such as the type and model, manufacturer, carrier name, and identifiers assigned to your device, such as Android Advertising ID, or internal device identifier.

 

  • Information about your online activity including which adverts served through Glispa Discover you viewed or clicked on, whether you visited the advertiser’s website or purchased the product or service advertised through Glispa Discover and what advertised applications are installed on your device due to use of Glispa Discover.

 

We use this information to provide and improve Glispa’s services, including for:

 

  • Serving ads: Allowing publishers to offer advertising inventory in their mobile apps, and advertisers to bid on and fill that inventory.

 

  • Ad reporting and conversions: Reporting to advertisers information about when and how users have been shown their ads, clicked on their ads, and reporting to publishers information about when and how ads were shown on their properties and were clicked on.

 

  • Frequency capping: Preventing users from seeing the same ad too many times.

 

  • Fraud detection and prevention: Identifying invalid clicks (or ad queries) and protecting Glispa Customers from fraudulent behaviour.

 

  • GeoTargeting: Where permitted by the user’s device, allowing Glispa Customers to serve ads based on a user’s location.

 

  • Providing and improving our services: Auditing, researching, and analysing data in order to maintain, protect, and improve our services and develop new services, and to ensure that our technologies function properly.

When you contact us

If you contact us by telephone, email, post or using any other function offered by our website, we may collect your name, contact details, employer details, location and any other information that you provide to us.

We will use this information to review, investigate and respond to your questions or comments as necessary. Please note that we may record telephone calls made to us.

When you register with us

If you register with us as a publisher or advertiser, or as a customer of Glispa Create, we will collect your name, contact details, employer information (if relevant), payment information, tax registration number.

We will use this information to:

  • create and maintain your account with us;
  • carry out our obligations arising from any agreements entered into between you and us;
  • respond to your queries and support your needs efficiently;
  • notify you about changes to our service or our products;
  • comply with any legal obligations to which we are subject; and
  • protect and defend our rights and interests.

When you sign up to receive marketing emails from us

If you sign up to receive emails from us, we will collect your name, email address, employer details (if relevant) and location.

We will use this information to send you emails about services we think you may be interested in,   updates about us and/or the website and to notify you of any changes to our services.

If we need to verify your identity

In some circumstances we may be required by law or by our internal compliance procedures to take steps to verify the identity of the owners or companies officers of companies that we do business with. These checks are sometimes called “know your client” or “KYC” checks. As part of this process we will ask relevant individuals to provide certain information such as name, address and nationality. We will also ask for documentary evidence verifying these details, such as a copy of the individual’s passport and/or utility bill.

We will use the information that provided us for the purpose of complying with our legal or internal compliance obligations. Our legal basis for processing this personal information is that it is necessary for compliance with a legal obligation to which we are subject, alternatively that it is necessary for our legitimate interests in ensuring that we are conducting our business in a responsible way which complies with our internal standards.

Glispa Perform

If you interact with a website or app that uses Glispa Perform, we may receive limited amounts of personal information about you, including:

  • Information about your online activity including which adverts you viewed or clicked on and whether you visited the advertiser’s website or purchased the product or service advertised.

 

  • Device information such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser, and the version of such applications, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or mobile  device identifier.

 

  • Log information, including the app or website visited, session start/stop time, time zone, language, and network connection type.

 

We use this information to provide and improve Glispa’s services, including for:

 

  • Serving ads: Allowing publishers to offer advertising inventory in their mobile apps, and advertisers to fill that inventory. We may also use information about you that advertisers give us to deliver tailored adverts to you.

 

  • Ad reporting and conversions: Reporting to advertisers information about when and how users have been exposed to their ads, clicked on their ads, and reporting to publishers information about when and how ads were shown on their properties and were clicked on.

 

  • Frequency capping: Preventing users from seeing the same ad too many times.

 

  • Fraud detection and prevention: Identifying invalid clicks (or ad queries) and protecting Glispa Customers from fraudulent behaviour.

 

  • Providing and improving our services: Auditing, researching, and analysing data in order to maintain, protect, and improve our services and develop new services, and to ensure that our technologies function properly.

Glispa Retargeting

Third party advertisers and brands whose websites or apps you use may provide your personal information to us in order for us to tailor advertisements to make them more relevant you. The information we will receive about you includes:

  • Information about your online activity including products you have viewed and/or purchased.

 

  • Device information such as identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or mobile device identifier.

 

We use this information to provide and improve Glispa’s services, including for:

 

  • Serving ads: To deliver tailored adverts to you.

 

  • Ad reporting and conversions: Reporting to advertisers information about when and how users have been exposed to their ads, clicked on their ads, and reporting to publishers information about when and how ads were shown on their properties and were clicked on.

 

  • Frequency capping: Preventing users from seeing the same ad too many times.

 

  • Fraud detection and prevention: Identifying invalid clicks (or ad queries) and protecting Glispa Customers from fraudulent behaviour.

 

  • Providing and improving our services: Auditing, researching, and analysing data in order to maintain, protect, and improve our services and develop new services, and to ensure that our technologies function properly.

Third Party Service Providers

We also work closely with third party service providers including, for example, business partners, sub-contractors, advertising networks, analytics providers and search information providers (“Third Party Service Providers”).

We may receive information about you from Third Party Service Providers such as Google Analytics, Intercom, Hubspot and  Hotjar. We may share some of the information we collect from you with Third Party Service Providers (see “Disclosure of Your Information” below).

When you use our website, we may automatically collect information  including:

 

  • Information about your visit, such as:
  • the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time);
  • page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
  • the third party website from you linked directly to the website (if applicable; and
  • methods used to browse away from the page and any phone number used to call our customer service number.
  • Technical information, such as :
  • the internet protocol (IP) address of your device;
  • mobile device ID (see below);
  • your log in information;
  • browser type and version;
  • location and time zone setting;
  • browser plug-in types and versions;
  • operating system and platform; and
  • cookies (see below); and

Cookies are small text files that are stored on your computer. Cookies allow us to analyse the way our website is being used by you. You may prevent your browser from saving Cookies by adjusting the corresponding settings in your browser software.  However, please be advised that in such case, you may not be able to use all functions on website and/or on third-party sites to their full extent.

To opt out of personalized ads served in apps on your mobile device, follow the instructions below.

If you have an Android device:

  1. Find Google Settings. Depending on your device, it could be located:
    1. in a separate app called “Google Settings”, or
    2. in your main “Settings” app, scroll down and tap “Google”
  2. Tap “Ads”
  3. Switch on “Opt out of interest-based ads”

If you have an iOS device:

You can opt out of interest-based advertising by updating to iOS 6.0 or higher, and setting “Limit Ad Tracking” to ‘ON. You can do this by clicking on Settings – > General – > About – > Advertising and toggling “Limit Ad Tracking” to ‘ON.

When you have opted out using these settings on a device, Glispa will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests. Glispa requires its partners to honor opt-out preferences expressed using these controls. However, please note that opting-out using these settings would only prevent serving tailored ads to you; this would not affect other activities, such as serving contextual advertising, ad frequency capping and analytics.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/choices  , or www.youronlinechoices.eu and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics by following this link: https://tools.google.com/dlpage/gaoptout

Our legitimate business interests

If we have collected your personal information directly from your device, or if it has been provided to us by a publisher or advertiser, our legal basis for using your personal information is that it is necessary for our legitimate interests in conducting our business and facilitating the serving of adverts.

If you are a publisher or advertiser, or an employee of a publisher or advertiser, and we have collected your information in the course of our commercial relationship or in order to market to you, our legal basis for processing your personal information is that it is necessary for our legitimate interest in performing the contract between us and the business you are associated with.

Consent

If you have downloaded an app that has integrated the Glispa SDK, our legal basis for the installation and operation of the SDK, including the collection of information from your device, will be your consent. App publishers collect this consent on our behalf.

If you sign up to receive marketing messages from us we will contact you from time to time with information about Glispa services and events that we think may be of interest to you. We may base these messages on pages you have viewed on the website.

You can opt out of receiving further marketing messages at any time by clicking the “Unsubscribe” link in any email you receive from us.

We may share your personal information with any member of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, from time to time (our “group”).

We may share your information with selected third parties including:

  • Advertisers and advertising networks, to enable them to decide whether to bid for advertising space, whether to serve an advertisement and which advert is best for a particular device.

 

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them and/or you.

 

  • Analytics and search engine providers including Google Analytics, Intercom, Hubspot and Hotjar that assist us in the improvement of the website.

 

  • Third party service providers such as Amazon Web Services, to help us operate our business, the website or administer activities on our behalf, such as sending out newsletters or surveys.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.

 

  • If we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.

 

  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect our rights, property, or safety, or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

We do not sell, trade, or rent your personal information to others.

The personal information that we collect from you will be transmitted to third parties located in countries outside of the European Economic Area (“EEA”) including the United States and Israel.

If you would like more information about how your personal information is transferred, and the safeguards applied, please contact us at contact@glispa.com.

The period for which we will retain your personal information will vary depending on the purposes it was collected for, as well as the requirements of any applicable law or regulation.

For example, if you engage our services, we will store your personal information and details about your order for as long as is necessary to comply with applicable tax legislation, and for the period for which you or we could bring legal proceedings in relation to the services.

You may have certain rights in relation to the personal information we collect about you. These may include the right to request access to the data we hold about you, or to obtain a copy of the personal information in machine readable format, to request that it is erased or that any inaccurate personal information is rectified. You may also have the right to ask us to restrict how we process your personal information  or to withdraw your consent to how we process your personal information.  Please contact contact@glispa.com if you would like to make a request.

You also have the right to complain about the use of your personal data to the Supervisory Authority, which in Berlin is the Berlin Data Protection Authority; An der Urania 4 – 10, 10787 Berlin (www.datenschutz-berlin.de).

The website may, from time to time, contain links to and from the websites of our partners, affiliates, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content on these websites and We are not responsible for the practices employed by them. If you follow a link to any of these websites, please note that these websites have their own privacy and customer support policies and we do not accept any responsibility or liability for these policies. Please carefully check these policies before you submit any personal information to these websites.

This policy will be reviewed from time to time to take account of changes to our operations and practices. If we make changes, we will notify you by revising the date at the top of this policy, and if the changes are significant, we may provide you with additional notice, such as adding a statement to the homepage of the website or sending you an email with the update. Any personal information held will be governed by our most current policy.

If you have any questions or requests regarding this privacy policy, the practices of the website or your dealings with the website, please contact contact@glispa.com.