Thank you for your interest in SPORRY.COMand in our services. This Data Privacy Policy offers you information about how we deal with your personal and non-personal data as a visitor of our website, whether we collect data from you as a Client (Advertiser or Publisher) or whether you are a User (visitor of our clients' websites and platforms). The collection, processing and use of your data takes place in compliance with all applicable data protection regulations. By visiting any of our websites or sharing any information with us, you agree to be bound by this Data Privacy Policy.
SPORRY.COMimplements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, ensures data is only transferred internationally with a lawful basis, only contracts with processors and sub-processors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.
Personal data comprises all information that directly or indirectly can be referred to a natural person who is alive, e.g. name, postal address, e-mail address or phone number. Non-personally identifiable data is information that cannot be connected to a person's real identity, e.g. the number of users visiting our website or other any other kind of aggregated information.
SPORRY.COMcomplies with all applicable privacy legislation. For the purposes of compliance with The General Data Protection Regulation (GDPR) (EU) 2016/679 ("GDPR"), a controller of personal data is the natural or legal person who processes personal data and who decides why and how such data shall be processed. SPORRY.COMis the controller of personal data provided by you through the SPORRY.COMwebsite ("Our Website"). Personal data for which SPORRY.COMis the controller may be provided by you to us in the following situations: (i) if you are a Client you may be required to provide us with personal and corporate information, such as name, address, email address and other account information, to be able to access and use our services; (ii) as part of our sales efforts, we may collect and store data through online forms for contact purposes; (iii) if you are a prospective Client, you may provide us with personal data through Our Website when applying to join our network or via email when corresponding with our sales representatives; (iv) you may provide us with personal data when you send us inquiries relating to our services or in relation to this Data Privacy Policy.
The collection of personal data is based on legitimate interest according to the above and for the performance of a contract to which you and SPORRY.COM are the parties.
Clients confide in us for effectively marketing their products and services to customers online. By providing our technologies and services we may collect information about your device, its unique ID, operating system and browser as well as your IP address. The way you get in touch with us or our technologies and services determines the scope of how we collect and process personally identifiable information. Data as a general term may include all kinds of information such as your name, your address or information on your device (e.g. your operating system or browser).
a. When visiting our website SPORRY.COM
This section provides information on how and which data we may collect from visitors of Our Website. We do not record any personal data (not your name, address, telephone number or email address) other than what is voluntarily provided by you when attempting to contact us via Our Website or attempting to enter into a contractual relationship.
i. Cookies
Our Website uses cookies. Cookies are small text files that are sent from our servers to your browser to be stored on your device. The cookie stores information, which is linked to respective devices used. Cookies help to improve and optimize the usability of websites and other online services, including our own websites and online services and those of others. If you are a registered publisher, the cookie will also manage and control your login and session on those parts of Our Website that are only available to registered publishers. Our use of cookies is strictly compliant with any applicable cookie and data privacy legislation.
Visiting and surfing on our website is possible without cookies. Most browsers accept cookies automatically. You may delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device. You may also alter the security settings of your web browser to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites only, or to be notified before receiving cookies. Please note, however, that these settings may have negative effects on the usability and user guidance of websites and other online services. If you are a registered publisher, certain parts of Our Website may only be used fully if your browser allows cookies.
You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org.
Cookies used on our website are listed below.
|
Cookie name |
Purpose |
|
_ga |
Analytic cookies by Google Analytics, please find more
information: |
|
Wp32058 |
Third party cookie placed by Act-on for marketing and aggregation purposes. For more information about Act-On's cookies, please visit https://university.act-on.com/User_Guides/Inbound_Marketing/The_Website_Prospector/Beacon_Tracker_Overview |
ii. Third Party Cookies
Cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party's website for more information about cookie management and how to "opt-out" of receiving cookies from them.
If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative, please visit www.networkadvertising.org/choices.
b. When you are our Client or becoming one
You need to register in our Network to obtain access to our platform and services as a publisher. If you enter into a contractual relationship with us and/or register in our Network, we record all data, including personal data, which has been provided by you such as your name, address, telephone number, email address. You can see from our online registration form which personal data in detail we record. We do not record any further personal data other than voluntarily provided by you (e.g. in response to a request for information).
In the event of your application to become a Publisher of SPORRY.COM is not successful, your information will be stored by SPORRY.COM for archiving purposes and will not be shared with any third parties unless it is in response to a demand by law enforcement authorities in connection with a criminal investigation, or by civil or administrative authorities in connection with a pending civil case or administrative investigation.
By registering with our Network you give your consent that we may contact you via telephone, via mail and email in order to provide you with information on SPORRY.COM offers. You may withdraw your consent at any time.
c. When using our services via websites and online services of our clients
We use cookies to provide our marketing services. We store cookies on devices of users who are visiting websites and using online services of our clients in order to record business transactions (leads and sales such as signing up for a newsletter or placing an order in a web shop). The only purposes of our tracking cookies are to allocate one successful advertisement to a particular business transaction, and to perform corresponding billing services. Tracking cookies only store information on when and on which device a click on an advertisement occurred. The data stored in our cookies is not attributed to a particular user and may contain hashed information (i.e. information in the forms of numbers and letters) on (i) the specific time of the user's action (click or view); (iv) hashed IP address to verify if a user is eligible for a marketing offer; (iii) device information (operating system and browser type) to verify eligibility for a marketing offer (iv) information indicating whether user converted on a marketing offer.
Our tracking cookies
are listed below.
|
Cookie name |
Purpose |
|
ho_mob |
This is a hash of
the user's device/connection information. This hash is used for offer
targeting. |
|
enc_aff_session_* |
This is an offer
specific cookie. It includes the user's transaction_id and IP address for
tracking conversions. The * denotes the offer ID. There will be a different
version of this cookie for each offer that is clicked |
|
Aff_conversions |
This cookie stores
the offer_id of all offers that the user has converted for () |
We use personal data provided by our clients only for administrating and providing our services, for responding to clients' inquiries and, where applicable, executing the contract between a client and SPORRY.COM, including payment processing. We store personal and any other kind of data strictly in compliance with applicable data protection and privacy legislation and our contractual duties, and will prevent unauthorized access to data to the best of our abilities.
We may transmit your data to our subcontracted service providers, but only if we contractually assigned these providers to process data on our behalf and, both ourselves and the subcontracted service providers comply with all requirements of applicable data processing regulations pursuant to laws on data protection.
In order to fulfill our contractual obligations we may transmit your data to companies that we control and subsidiaries of such, provided that these companies are subject to this Data Privacy Policy or privacy guidelines ensuring at least equal protection of your data.
We do not transmit data to other third parties unless you have given your consent thereto; the transmission is required by law, or in response to a valid order or ruling by a court or other governmental body; or in order to protect our rights or enforce contractual terms we may have with you.
SPORRY.COM takes all technical, physical, and organizational security measures required to protect your personal data from loss, unauthorized disclosure or other forms of misuse. Data is stored in a safe environment that is not open to public access. Our staff has been trained in privacy matters and in dealing with data and information, which they gain access to in a responsible manner.
You have the right of access to your personal data at any time and may demand rectification.
In case you registered as a Publisher, you may access your publisher account and rectify some of your data yourself. In all other cases you may request rectification by contacting us at the address listed below.
If retention of your data is no longer necessary for the purpose pursued or retention is no longer allowed for any legal reason (for example pursuant to an applicable right to erasure requests), we will erase your data and while observing applicable privacy legislation. We may restrict processing instead of erasing your data where legally not allowed to erase (e.g. legal obligations to maintain your personal data) or if legal right to erasure does not apply.
SPORRY.COM may share some or all of your personal data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the unlikely event of an insolvency, bankruptcy, or receivership, personal data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Data Privacy Policy. Regardless of any choices you make regarding your personal data, SPORRY.COM may disclose personal data if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on SPORRY.COM; (iii) to protect or defend the rights or property of SPORRY.COM or users of Our Website; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law or this Data Privacy Policy.
We may modify this Data Privacy Policy from time to time, in particular if new laws and regulations need to be adopted or we regard amendments reasonable. The date of amendments will be posted below the heading of this Data Privacy Policy.