Privacy Policy

This Privacy Policy explains how HeadBidder collect, use, and disclose information, and your choices for managing your information preferences. The data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners.

Acceptance of Terms

Please read this policy carefully since by visiting this website (“Website”) and/or sharing information with us, you agree to be bound by this Privacy Policy. The Privacy Policy may be revised or updated at any time by us. This page was last updated as of the date at the top of this Privacy Policy.

Definitions

Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. If natural person could not be identified by particular data without additional information or reference this data in not Personal data.

Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law, the controller or the specific criteria for its nomination may be provided for by law.

Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

What This Policy Covers

This Privacy Policy describes HeadBidder’s data practices associated with our corporate website (HeadBidder.net) and HeadBidder services (“Services”), and the choices that HeadBidder provides in connection with our collection and use of your information. This Privacy Policy is intended for both website publisher customers (“Publishers”) and individual users of websites and apps. For Publishers, this Policy explains how HeadBidder may collect, use and disclose information associated with your company and with your company’s websites and apps that use HeadBidder Services. For individual website and app users, this Privacy Policy explains how HeadBidder may collect, use, and disclose information when you visit our website or when you use any website or app that uses HeadBidder Services.

HeadBidder Services include Header Bidding Manager, a Web-based tool that enables publishers, and ad networks to efficiently sell digital ad inventory. HeadBidder also offers services, such as our Ad Server, through which we act as a service provider to enable our Publishers and other clients to manage their advertising inventory and to collect and use statistics data. In this case, Publishers may use our services to process data, which they collect or source. Publishers and other clients may also have their own policies that govern how they collect, use, and share data. These policies may differ from HeadBidder’s policies described in this Privacy Policy. Please consult the privacy policies of the websites you visit to become familiar with their privacy practices and to learn about any choices that these companies may offer with respect to their information practices.

Finally, the HeadBidder website may contain links to websites or content operated and maintained by third parties, over which we have no control. We encourage you to review the privacy policy of a third-party website before disclosing any information to the website.

Information Collection and Use

HeadBidder collects contact information through our website when you choose to provide it, such as your name, username, or email address. For example, you may be asked to provide us with contact information when you register with the HeadBidder website and when you purchase the Services. The decision to provide this information is optional. If you elect not to register or provide such information, you may not be able to access certain content, features, or services available on or through the HeadBidder website. In order to receive payments HeadBidder uses third party payment provider which require to provide payers Personal information to process payments legally. We encourage you to review the payment processors’ privacy policy on its website before disclosing any information.

HeadBidder uses this contact and billing information to operate and improve our Services, such as to provide notices about your Service, to fulfill your service requests, or to request your feedback or conduct research. HeadBidder also uses contact information to send you information about new products or Services; where HeadBidder needs your permission to do this, we only send such information in accordance with any permissions granted (Consent).

With respect to data collected via the HeadBidder Service, behalf of our Publishers and Clients, we collect statistical information that does not directly or indirectly identify an individual natural person. The information we collect is used to provide Publishers with statistical information about ad delivery on their Websites. Statistical data is Pseudonymised and Sampled so represent not a particular natural person but a mass of inventory grouped by one or several statistics-based terms. Such information may include:

• Browser information (URL, Browser type, User-Agent)
• Ad reporting or delivery data (Size of ad, Ad impressions, Bid requests)
• Device-type information (Screen dimensions, Device type)
• Location data (IP address, Country)

HeadBidder does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA) and does not allow Children to become platform user by Terms. If you believe that HeadBidder has inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact HeadBidder using the contact information below to request deletion of the information.

• Elman Systems Limited does not collect and store card data,
• Elman Systems Limited merchant will not sell, purchase, provide, exchange or in any other manner disclose Account or Transaction data, or personal information of or about a Cardholder to anyone, except, it’s Acquirer, Visa/Mastercard Corporations or in response to valid government demands.

Cookies and Other Similar Technologies

We use cookies (a small file containing a string of characters that uniquely identifies your Web browser) to operate and improve our website and Services.
We use the following categories of cookies for our website and Services:

Strictly Necessary Cookies

These cookies are essential in order to enable you to navigate our website and use its features, to collect and store information about ad delivery on Customers’ web-sites. Without these cookies, Services you have asked for such as remembering your login details or browser parameters cannot be provided.

Performance Cookies

These cookies collect anonymous information on how people use our website. For example, we use these cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve, such as navigation and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

Functionality Cookies

These cookies remember choices you make such as the country from which you visit our website, language and search parameters. The information these cookies collect is anonymized and they cannot track your browsing activity on other websites.

Publishers that participate in the HeadBidder may also utilize cookies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through cookies or similar technologies by such third parties will be governed by their own privacy policies and principles, which HeadBidder does not control.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. How-ever, please note that certain features of the HeadBidder website may not work if you delete or disable cookies. Moreover, if you delete cookies after previously opting out of HeadBidder’s practices, you may need to renew your opt-out choice.

How to refuse or be warned of the installation of all “cookies” files? You may decline the saving of “cookies” by configuring your browser.

• Chrome users: https://support.google.com/chrome/answer/95647
• FireFox users: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website- preferences
• Safari users: https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=en_US
• Internet Explorer users: http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11

Information Sharing

We will disclose contact and billing information to third parties only as described in this Privacy Policy:
with your express permission;
with our affiliates, which include entities controlling, controlled by, or under common control with HeadBidder;
where we contract with third parties to provide certain services, such as advertising, analytics, data management services, web hosting, and web development (“Service Providers”). We ask Service Providers to confirm that their privacy and security practices are consistent with ours, we provide our Service Providers with only the information necessary for them to perform the services we re-quest, and Service Providers are prohibited from using such information for purposes other than as specified by HeadBidder;
in the event that HeadBidder is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer information in connection with such transaction; and
where we believe it is necessary to protect HeadBidder or our users; to enforce our terms or the legal rights of HeadBidder or others; or to comply with a request from governmental authorities, legal process, or other legal obligations.
We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above.

HeadBidder may also be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Protection

We use reasonable and appropriate security measures to protect your data. We may change the Privacy Policy at any time by posting the revised Privacy Policy on the Website and if such changes are material, a notice of the changes will also be posted along with the revised Privacy Policy.

Members of the Header Bidding Manager Platform include website owners involved in advertising campaign transactions. Member information collected includes Personally Identifiable Information that is necessary to conduct business, such as name, phone number, and email address. Payments made to Header Bidding Manager Platform require the collection of Personally Identifiable Information that may include credit card numbers and bank account information. Phone numbers may be used to contact Users. All Member information is collected, modified and stored in a password protected environment. This information is used for service, media delivery, contact, billing. We will not sell, share, or rent this information to non-Header Bidding Manager Platform entities. All Member information collection is explicit, voluntary, manually entered by the User.

If you have any questions about this Privacy Policy, the practices of or your dealings with us relating to this Privacy Policy, please email us at privacy@headbidder.net

Legal Basis for Processing Personal Information of European Economic Area (“EEA”)

Individuals On certain occasions, HeadBidder relies on the consent of the individual to process personal information (for example, when the user inputs personal information into the HeadBidder website). On other occasions, HeadBidder may process personal information when HeadBidder needs to do this to fulfill a contract or where HeadBidder is required to do so by law.

HeadBidder may also process data when it is in HeadBidder’s or its customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Those legitimate interests include improving HeadBidder’s Services.

Your rights as the Data Subject

HeadBidders’ User Account Console is the preferred way of accessing your personal data. The console facilitates the possibility for you to exercise a number of your user rights in terms of personal data:

• The right to object to processing – You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
• The right to be informed – You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
• The right of access – You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
• The right to erasure – This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
• The right to rectification – You are entitled to have your information corrected if it’s inaccurate or incomplete.
• The right to restrict further processing – You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
• The right to data portability – You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

Reviewing and Updating Information

HeadBidder takes reasonable steps to ensure that information is accurate, complete, current, and reliable for its intended use. For contact or billing information submitted through our website, you may review, correct, update, or change your information, request that we deactivate your account, or remove your information from our direct marketing efforts, at any time by e-mailing us at privacy@headbidder.com.

Opt-Out

If you no longer wish to use Header Bidding Manager Platform Services, you may opt out of Platform by canceling your account.

Security

Header Bidding Manager Platform employs appropriate measures to ensure the security of all Information and We routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.

Changes

As the standards governing Internet privacy continue to evolve, Header Bidding Manager Platform may find it appropriate or necessary to update this Privacy Policy from time to time. As a result, we reserve the right to change this privacy policy at any time and shall post such changes on the Website. Our Website will state the date the Privacy Policy was last updated. We encourage you to review the Privacy Policy whenever you use this Website to make sure you understand how your information will be used.

Your Representations

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS.

You also agree that you have provided notice to, and obtained consent from, any third party individuals whose Information you supply to us with regard to:

• the purposes for which such third party’s Information has been collected;
• the intended recipients or categories of recipients of the third party’s Information;
• which of the third party’s data are obligatory and which data, if any, are voluntary;
• how the third party can access and, if necessary, rectify the data held about them.
• It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language.

Last update: December 01, 2022

FM Labs LLC
201 Spear St, 1100 #3001
San Francisco, CA 94105, USA
+1 415 508 4529
support@headbidder.net

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