GothamAds Privacy Policy

The following describes the overall company privacy policy (the “Privacy Policy”) of GOTHAMADS LLC (hereinafter referred to as the “Company”) in relation to the use and disclosure of information You share via this website (hereinafter referred to as “Website”, “Us”, “We” or “Our”). The Privacy Policy was created to inform You what information we collect when You visit our website as well as our customer's and how that information is collected and used by our customers ("Demand and /or Supply Partners").

We are providing You with this Privacy Policy to help You make an informed decision as to whether to use or continue using the website. The Company reserves the right to update the policy periodically, and these updates are effective upon posting. It is imperative that this document is read thoroughly and often.

This Privacy Policy applies to the information that we collect or receive from You and other individuals who use the website, register on the website or participate in the promotions or offers available on the website; or with whom we communicate through email or other means.

Your privacy and security are of the utmost importance to us. We will always follow these principles:

• Lawfulness, transparency and fairness;
• Purpose Limitation;
• Data Minimization;
• Accuracy;
• Storage limitation;
• Confidentiality and integrity.

The Company does not seek any personal information by illegal means. We collect only necessary information from You and other individuals who use the website (Demand Partners and/or Supply Partners) by means of online or offline surveys, order forms, registration pages, telephone or cellphone communication, and other similar means.

We collect information from and about users of the Website:

• 1. Directly from You when You provide it to us through the Website; and
• 2. Automatically when You use the Website (some information – such as IP address and/or browser and device characteristics).

When You are filling out forms via the Website, We may ask You to provide information:

a) by which You may be personally identified, such as name, company name, email address, or any other personal or personally identifiable information under applicable law, and/or

b) that is about You but individually does not identify You.

This information may include:

• Information that You provide by filling in forms on the Website at the time of registering in order to use or access the Website.
• Records and copies of Your correspondence (including email addresses), if You contact Us;
• Your responses to surveys that We may ask You to complete for research purposes.

While You use the Website, We may collect certain personally identifiable information that can be used to contact or identify You which also includes: IP Address, cookies, usage data. This personal information is necessary to manage the Website, communicate with You about the Website, and for other purposes set out in this Privacy Policy.

You voluntarily consent to the collection, use and disclosure of such personal information by providing personal information to us and by continuing to use the Site. Without limiting the aforesaid, if appropriate, You may be asked to provide Your consent when We collect, use, or disclose Your personal information in particular circumstances.

Personal information is any information that can be used to distinguish or trace an individual's identity, either alone or in combination with other information, or may be of private or sensitive nature. As part of this voluntary registration, we may request contact information (such as name, mailing address, email address, etc.) and other information required for operating these services. We may only collect personal information from You if You voluntarily provide it. By voluntarily providing this personal information to Us, by sending Us a comment or suggestion, You will be consenting to the collection, use and distribution of Your personal information by Us for the purposes set out herein.

Non-Personal information is information that cannot be used on its own to identify, trace, or identify a person, i.e. information without particular reference to the identity of the user from which such information was collected.

When You visit our Website, information about Your visit (e.g. how You navigate the site) may be collected and stored. This information may include the length of Your visit, the date and time of Your visit, the pages You look at and the sites You visit before and after leaving Our site. It does not include personally-identifiable information such as Your name, mailing or email address or telephone number. We use this non-identifiable and aggregate information to better design Our website and for the purpose of optimizing Our services and/or business. We also may share this general non-identifiable information with our affiliates, suppliers, sponsors and Demand Partners.

The Company uses Cookies to associate certain Internet-related information about You and other individuals who use the website (Demand Partners and Supply Partners) with information about You in our database.

A cookie is a small amount of data stored on the hard drive of Your computer that allows us to identify You with Your corresponding data that resides in our database. Cookies do not reveal personal information. The only personal information a cookie can contain is information You supply Yourself such as email address, purchases and preferences. Cookies cannot read data from Your hard drive. If You want to delete cookies from Your computer, please go to Your browser settings and doit manually.

When You log in to access Your account, our servers may automatically record and archive certain information that web-browsers send whenever visiting the website. These server logs may include information vital to validating Your authorization to access the account. Information, such as a web-request, Internet Protocol (the "IP") address, browser type, browser language, referring pages, exit-pages and visited URLs, platform type, click counts, pages viewed and in what order, time-spent, date and time of the request, and other important data is necessary to validate and authorize Your entry and activity on the website.

Credit Card Information includes credit card numbers and related information, such as the expiration date of the card, etc. We do not collect Your Credit Card information on our website.

The Company will only use information provided by You and other individuals who use the website (Demand Partners and Supply Partners) for purposes that You have provided it for, including those to operate, provide, improve, and maintain our website and services; to respond to Your inquiries and provide other customer services; as well as for other administrative and internal business purposes.

Your Personal data will be used to establish Your account, to communicate with You and for ongoing record keeping, required by the Company.

Your Non-Personal Data Information including cookies, etc., will be used only for system administration and for improvement of our services (e.g. to keep track of visitors sent by the Company's Partners to Demand Partners' websites). This ensures our Partners get credited for services they provide to Demand Partners, and Demand Partners get complete package of services the Company provides.

Your log information is necessary to validate and authorize Your entry and activity on the website.

Where we have given You (or where You have chosen) a password which enables You to access certain parts of our Website, You are responsible for keeping this password confidential and for complying with any other security procedures that we notify You of.

General Data Protection Regulation (EU) 2016/679 (GDPR) is a European Union law governing privacy and data protection for all residents of the EU. The provisions of GDPR can be also applied to how data is processed and verified outside the European Union.

GDPR is intended to empower the citizens of the European Union to control their personal information. In accordance with the applicable laws, users are authorized to access and modify their own data held by the companies, which includes data collection, ad tracking, surveys, cookies, location data, and every other bit of a user’s “digital footprint”. Users are also entitled to transmit their personal details to other organizations. The GDPR also enforces companies to determine their in-house data security policies.

We maintain our commitment to protect the privacy of our users and abide by the legislation of all regions we operate in, including compliance with the GDPR.

Taking into account the above, personal data (if any) of our users is processed under the “purposes of legitimate interests” as outlined in GDPR Article 6(1)(f). Such an approach also helps us to fight against fraud and reimburse our contractors and agents. In accordance with the GDPR requirements, we will strive to, at any time, (i) streamline the data handling controls, (ii) specify our relationships with data partners, and (iii) provide the data subjects with an understanding and direct management of the way their personal information is used.

Personal Information: Personal information will be pseudonymized and encrypted to ensure the user privacy. The collected information will be handled for standard cases of use described in this Privacy Policy.

We will, to the best of our ability, make sure that our sub-processors operate in full accordance with GDPR requirements before starting cooperation with them and require such sub-processors to comply with this Privacy Policy and maintain appropriate security to protect user information from unauthorized access or processing, unless we have no ability to do so (for example, where we are sharing information with regulatory authorities or courts). Nevertheless, we cannot be held responsible or liable for the use of any information that a sub-processor may execute, or that is gathered by sub-processors. Whenever applicable, users should acquaint themselves with Privacy Policies of any of the involved sub-processors’ websites.

Data Retention: We will retain the gathered data for the period of the cooperation, but in no case longer than the maximum allowed by the existing legislation, unless You choose to withdraw it Yourself.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Gothamads strives to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

The General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. You (data subject) may send official requests to us regarding Your personal data via email to the following address: dpo@gothamads.com

At any time, You have the right:

• Right of access: the right to be informed of, and request access to, the personal data we process about you;
• Right to rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete
• Right to erasure: the right to request that we delete your personal data;
• Right to restrict: the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to object: the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
• Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to automated decision-making: the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. Your request will be executed no later than 30 (thirty) days from the initial request receipt but we will do everything possible to process it within the first 48 working hours.

Should a data breach related to Your personal information occur, we will notify a relevant supervisory authority within 72 hours thereof.

According to the California Consumer Privacy Act (“CCPA”) then amended by The California Privacy Rights Act (CPRA) the California residents have the following rights listed in this clause:

You have the right to know and see what information we have collected about you over the past 12 months, including: the categories of information we have collected about you; the categories of sources from which the information is collected; the business or commercial purpose for collecting your information; the categories of third parties with whom we have shared your information; and the specific pieces of information we have collected about you.

You have the right to request that we delete or correct the information we have collected from you (and direct our service providers to do the same).

There are a number of exceptions, which includes (but are not limited to) when this information is necessary for us or a third party to do the following: complete your transaction; provide you a good or service; perform a contract between us and you; protect your security and prosecute those responsible for breaching it etc.

You have the right to “opt-out,” or direct us to stop “selling” or otherwise sharing your information with third parties in exchange for money or other valuable consideration.

To submit an opt-out request, please contact us at dpo@gothamads.com and/or submit the required verifying information, by contacting us here.

Gothamads comply with the principles and requirements of data processing under the Lei Geral de Proteção de Dados Pessoais (LGPD), including, but not limited to, age-gating requirements. All the data received by using our services is anonymized and therefore falls outside the scope of LGPD.

You have the following rights under the LGPD:

• Confirmation: confirmation of the existence of processing;
• Access: access to the data;
• Rectification: correction of incomplete, inaccurate or outdated data; anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of LGPD;
• Data portability: portability of the data to other service providers or suppliers of product, at the express request;
• Anonymization: anonymization, blocking or elimination of the personal data processed with the consent of the data subjects, except in the events set forth in article 16 of LGPD;
• Deletion: You have the right to have their personal data deleted if the processing of that data was based on consent;
• Information: You have the right to be informed about sub-processors and other third parties that access or process their personal data. You also have the right to be informed about Your consent choices and the consequences of refusing consent;
• Revocation: revocation of the consent, pursuant to the provisions of paragraph 5 of article 8 of LGPD;
• Bring complaint: lodging a complaint with the Data Protection Authority;
• opposing the processing of personal data where there is non-compliance with the provisions of LGPD;
• Request review: You have the right to request the review of decisions made solely on the basis of automated processing of personal data which affect Your interests. This includes decisions used to define Your personal, professional, consumer and credit profile, or the aspects of Your personality.

If you would like to exercise any of these rights, please contact us via: dpo@gothamads.com

Gothamads comply with all the principles and requirements of data processing under the Personal Information Protection Law (the “PIPL”), including, among others: accuracy, accountability and security, purpose limitation, collection limitation, openness and transparency, lawfulness and necessity.

You have the following rights under the PIPL:

• You have the right to know, decide, refuse, and limit the handling of their personal information by others unless laws or regulations stipulate otherwise;
• You have the right to access and copy your personal information in a timely manner, except when the laws and regulations require confidentiality;
• You have the right to correct or complete inaccurate personal information in a timely manner;
• You have the right to request Us to explain Our personal information handling rules;
• You have the right to deletion of Your personal information if (i) the agreed retention period has expired, or the handling purpose has been achieved; (ii) We as a personal information handler cease the provision of Our services; (iii) You rescind consent where the processing of personal information was based on Your consent; (iv) the information is handled in violation of laws, regulations or agreements;
• You have the right to request Us to transfer Your personal information to another personal information handler.

If you would like to exercise any of these rights, please contact us via: dpo@gothamads.com

Your email address will only be used for the purposes of contacting You in order to fulfill these services offered by Company. This may include notifications on offer changes, Your campaign updates, Company newsletters, notes about Your results, etc. Email addresses will never be provided to any third party, without a written approval, or an electronic consent from You. Users can opt out from Company newsletters and from other email related activities by adjusting settings of their accounts, by unsubscribing from the newsletters themselves using an opt-out link, or by providing the company with a written notice (email is sufficient).

Your Personal Information will not be shared unless we have first given You notice that we might share Your data, and You have authorized us to do so. The Company receives information from You and other individuals who use the website, and have the right to use this data (sometimes, in connection with Non-Personal data), but is generally prohibited from sharing this information with other companies or people.

Your Non-Personal data will not be linked with Your Personal Information or be shared, unless we have given You notice as described above and You have given us authorization to do so.

Security of Your information (Personal data and Non-Personal data) is our utmost priority. authorized employees have access to the information You provide Us. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we process which included:

• using secure shell protocol (SSH);
• multi-factor authentication;
• access control (physical and technical);
• link encryption

Our data is only stored in centers that provide the highest quality security for Your information. Only authorized employees have access to the information You provide Us.

We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a “sale” under the CCPA. We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction. To exercise these rights, You can contact us by email at dpo@gothamads.com. Whenever You have any question regarding the process of how we handle Your data, don’t hesitate to inform Us.