Company name: Amvisible LTD
E-mail: hello@adfixer.com
1. Introduction
Amvisible LTD (hereinafter also “ADFIXER” or “data controller”) is committed to protecting the privacy and security of your personal data. This Privacy Policy outlines how we collect, use, process, and retain personal data in accordance with the General Data Protection Regulation (GDPR).
2. Personal Data Collected
ADFIXER contracts exclusively with entrepreneurs who are mostly legal entities. Occasionally, a natural person, acting in its capacity as an entrepreneur, insofar as permitted by law, may also enter into contractual relations with ADFIXER. In view of the foregoing, the personal data collected by ADFIXER’s customers is narrowed down significantly. It encompasses the names of the legal representatives of the company and where a natural person is a contracting party - its name, address, IP address, payment instrument information, and possibly other details related to the purposes of processing described below.
3. Purposes for Which Personal Data is Collected and Processed
We gather and use personal information for the purpose of presenting our website, ensuring its functionalities, maintaining registered user profiles, and delivering our paid services, mainly in the form of subscriptions for a particular term. We would not be able to provide our services without the use of personal data as we would not be able to differentiate between the persons eligible to receive our services. Some information we are provided with is used to verify the customer’s identity by logging in and to follow up on password reset requests. Some of the personal data we process, such as credit card details, is processed to ensure that we will receive the remuneration for the services we provide. We process the names of legal representatives of our corporate clients in order to have a human point of contact and, where needed, to be able to determine their representative power and the validity of concluded contracts. Other identifying information, insofar as such is collected, is processed for the purpose of being able to effectively pursue our rights in case of legal disputes by sending letters, initiating lawsuits, etc. We process customer’s IP addresses to deliver various functionalities, which are often performed by third parties. Accordingly:
Due to our integration with amazon.com (AWS), we transfer IPs to AWS. AWS automatically logs customer visit and retains the information in server log files. This information contains the customer IP address, which may be personal data, along with other information, such as the date and time of access, the browser version, and the referrer URL (URL you visited immediately before). For the system to be able to transmit the webpage to your terminal device, the system must temporarily store the IP address. Your IP address must be kept on file for the duration of the session in order to serve this purpose. The aforementioned information is analyzed solely to make sure that our website operates continuously and without interruption and that our information technology systems are secure.
We utilize the service Google Tag Manager, which needs our customer’s IP addresses to operate. To help the user load our website more quickly, Google Tag Manager collects the majority of tracking pixels and scripts. With the Google Tag Manager, we can integrate Google Analytics and other Google marketing services into our online offering.
4. Legal Bases for Processing
We process personal data based on the following legal grounds as per art. 6 of the General Data Protection Regulation:
Performance of a Contract: The processing of personal data is necessary for the performance of contracts to which the data subjects are parties or to take steps at the request of the data subjects prior to entering into contracts.
Compliance with Statutory Obligations: We process personal data to fulfill legal obligations to which we are subject. Such statutory obligations include tax law and anti-money laundering duties to be able to identify contractual parties paying to ADFIXER.
Pursuing of Legitimate Interests: We process personal data also to be able to protect our rights and interests by being able to uniquely identify our contractual partners in order to send them notifications related to the obligational relations between the parties or being able to identify them in front of an adjudicating authority.
Consent: We process information of customer devices through cookies. For deployment of non-essential cookies, we rely on user’s consent. Customers have the right to withdraw their consent for processing without any adverse consequences. If consent is not given/withdrawn, we may continue processing this information only if compelling legitimate interests exist.
5. Data Retention
We retain personal data for the duration of the registration of our users and as required by applicable laws and regulations. After the contractual relationship ends, we may retain the data for a period necessary to fulfill legal obligations, establish, exercise, or defend legal claims, or as otherwise required by law.
Information of IP addresses that is being sent to AWS is kept for a maximum of 7 days.
6. Data Security
We implement appropriate technical and organizational measures to ensure the security of personal data. Technical measures include pseudonymisation with state-of-the-art encryption software. This also includes protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. Organizational measures include the separate keeping of data, and granting of access only to a limited number of persons who have clearly defined responsibilities in regard to data protection and others.
7. Data Sharing and Disclosure
We may share personal data with third parties only when necessary to fulfill contractual obligations or comply with legal requirements. Such third parties include web hosting operators, accountants, legal advisors, regulatory authorities, and other relevant stakeholders.
Your information may also be given to one or more processors (such as payment service providers), who will only use it internally on our behalf.
Data Transfer and Processing to Third Countries
A transfer of personal data to a country outside the European Union (EU) and the European Economic Area (EEA), including transfer in the form of processing of data via the use of third-party services delivered by a company incorporated in a third country, will be conducted only if the respective third country has a recognized level of data protection (i.e., there is an adequacy decision by the European Commission) and the respective processor is certified in accordance with any applicable local programs for data processing. Transfer may also be conducted where we have concluded an agreement with the processor under the so-called standard contractual clauses or there are certifications or binding corporate rules.
9. Use of Cookies
On our website, we utilize `cookies` to improve the user experience and enable access to specific features. These are small text files that your web browser stores on your device. Many cookies contain a unique identifier known as a `cookie ID`, which is a string of characters enabling servers and websites to associate with a specific browser where the respective cookie was saved.
Essential cookies vital for the functioning of our website are obligatory. Furthermore, cookies may serve to monitor user actions, aiding us in the ongoing enhancement of our website. Our website employs technically necessary cookies to facilitate your usage (such as storing your login details). Certain features of our website would be inaccessible without cookie usage. Even if the page undergoes changes, your browser needs to be identified for these functions. Disabling technically required cookies might curtail the functionality of our website.
Google Ads with Remarketing Pixel: We use Google Ads on our website, an online service that enables the placement of advertisements on third-party sites, which is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (`Google`), a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The ads that appear on our website are chosen by an algorithm that bases Google Ads on our website`s content. All visitors can be targeted based on interests using Google Ads, which is accomplished by building unique user profiles. Google accomplishes this through cookies. Your browser on your end device is automatically prompted to submit data to Google Ads for the purposes of online advertising and the settlement of commissions by each individual call of a page of our website on which a component of Google Ads has been implemented. In this way, Google learns about the personal information it needs to choose the kind of advertisement to play and track the number of times it is clicked. Google, among other things, Google can recognize that you have clicked on the advertising on this website.
Social Media: In addition to this website, we are active on a number of social media platforms. If you visit such a presence, personal information might be sent to the social network`s supplier. It`s likely that the social network`s supplier will process additional data in addition to storing the specific data you provided into the social network. Your information, for instance, will typically be used for marketing and advertising functions, including the creation of associated user profiles and the presentation of tailored advertisements to you. Your usage patterns and interests are saved in cookies for this purpose, which are typically stored on your terminal device by the social network provider.
YouTube: On our website, we embed videos from the social network youtube.com, operated by Google. When you access our website, your browser creates a direct connection to the YouTube servers. YouTube learns which precise sub-page of our website you are browsing as part of this technical procedure.
Newsletter and Email Analysis: Our newsletters may contain tracking pixels to analyze the success and reach of our email campaigns. This data is processed to understand user engagement and improve our communications.
10. Data Subjects RightsIf your personal data are processed, you have the following rights as a data subject within the meaning of the GDPR:
Right of Access (Art. 15 GDPR): You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and the additional information specified in Art. 15 GDPR.
Right to Rectification (Art. 16 GDPR): You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.
Right to Erasure (Art. 17 GDPR): You have the right to obtain the erasure of personal data concerning you without undue delay where one of the grounds specified in Art. 17 GDPR applies.
Right to Restriction of Processing (Art. 18 GDPR): You have the right to obtain restriction of processing where one of the conditions specified in Art. 18 GDPR applies.
Right to Data Portability (Art. 20 GDPR): You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
Right to Object (Art. 21 GDPR): You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6(1) lit. e or f GDPR, including profiling based on those provisions.
Right to Withdraw Consent: If you have given consent for the processing of your data, you can withdraw it at any time. Such withdrawal will affect the lawfulness of the processing of your personal data after you have expressed it.
Right to Complain to a Supervisory Authority: You have the right to lodge a complaint with a supervisory authority in the Member State of your residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated Privacy Policy will be posted on our website, and the date of the latest revision will be indicated.This Privacy Policy was last updated on [12.19.2023].