Privacy Policy

  1. General
    1. This document constitutes Privacy Policy of Cookie Market Ltd
with its registered office in London (address: 85 Great Portland Str., First Floor, London, England W1W 7LT) (hereinafter “Cookie Market”).
    2. This Privacy Policy is binding in relation to services provided by Cookie Market over the Internet. Those advertising services include, but are not limited to, interest-based advertising that includes also retargeting.
    3. You can contact us by writing to the address of our headquarter (see section 1.1 above), by e-mail [] and by phone: [+44 7367 171914].
    4. Should you have any queries related to processing of data described in our Privacy Policy, you may contact our (acting as) data protection officer at [].
  2. Data collection and processing
    1. We may process information about the use of services that we provide and services rendered by our clients. Such information does not constitute personal data ("usage data"). The usage data may include information such as:
      • technical data of users’ web browsers and operating systems,
      • regional settings and approximate location,
      • anonymized IP addresses,
      • numbers of users requesting services managed by us and our partners, along with time and duration of visits,
      • data regarding performance of our advertisements, including categories and profiles, to which users have been assigned to,
      • numbers of users displaying our advertisements, along with amount of impressions and clicks they generated.
    2. The usage data does not directly identify an individual and is not considered to be personal information, but specific types of the information such as non-anonymized IP address or cookies file, may be considered personal information in EU/EEA or if combined with other information. If such information may be considered personal information, we will treat such information as personal information.
    3. The source of the usage data are ours and our partner’s analytics systems. List of our partners is enclosed in the section 2.12 below.
    4. Usage data may be processed by us and/or our partners indicated in the section 2.12 below for the following purposes: analyzing the use of the services, user profiling, modelling, R&D ad targeting. The legal basis for such processing is user’s consent (collected through our website or through our partners’ websites) and our legitimate interests - namely advertising services of ours or of our clients’.
    5. We will take reasonable steps to provide the end user with clear and comprehensive information about the storing and accessing of cookies and other information on the end user's device if such activity occurs and where providing such information and obtaining such consent is required by law.
    6. We collect usage data in order to increase the relevancy of the ads being displayed to you i.e. advertisements of products you may be interested in and other advertising-related purposes. Our assessment of advertisements that may fall into the scope of user’s interest is done by verifying past browsing behavior of a user based on a cookie stored by the user’s web browser, and by assigning the user to one or more segments. Information collected through ads may also be used for further targeting or re-marketing. Statistical information about users and performance of advertisements may be passed to our clients – advertisers, enabling them to make conscious decisions regarding campaigns and assessing their effectiveness. Information may be also passed to third parties when it is technically required for displaying advertisements. We will also make the data available when it is required by applicable law.
    7. The usage data we collect may also be used to provide our clients and partners with in-depth information about the performance of their campaigns, and to improve campaigns effectiveness over time.
    8. We do not collect, use or process any personal data, including personal data of users such as name, gender, age, address, place of residence, personal identification numbers, phone numbers, e-mail etc. Also, we do not receive any additional data from our partners that could lead us to identify the user.
    9. We do not collect, use and process the data from users that we believe to be under the age of 16 years as well as any data from websites directed to children.
    10. We do not collect, use and process data that may belong to the special categories of data (such as data about political opinion, religion, health etc.).
    11. If there are no legal basis for the access to and the processing of data collected by us , our client or partner, we or our client or partner shall immediately cease collection and storage of such data and refrain from passing this data on to other parties, even if those other parties may have a legal basis.
    12. We stress that we do not share any personal data, we may only share usage data. For further information, please verify the privacy policies of the above listed entities.
  3. Cookies and other technical means
    1. We may store cookie files (small text files) containing anonymous, alphanumerical identifier on users’ computer systems telephone or other device from which you access.
    2. We may also use other technical means necessary to provide advertising services, such as tracking pixels (accessing cookie files) or mobile identifiers.
    3. Cookie files:
      • collect data regarding the use of the website, and their main purpose is to facilitate that use of the website and customize the website to user’s needs and expectations;
      • are placed on the user’s end device and may also be placed on behalf advertisers and partners cooperating with us;
      • do not store information constituting personal data of the user;
      • are not used to determine the identity of the user;
      • are used on the website, based on the acceptance of appropriate settings by the website user expressed through software settings, in particular through a web browser.
    4. The user may revoke or adjust the scope of any previously expressed consent to use cookie files on the website and delete them from his or her browser at any time.
    5. The user may also limit or disable cookie files in his or her browser at any time through the settings. In this case, however, the use of the website may be less efficient and the user may even not have access to certain content or be able to use some of the website's functionalities, and in extreme cases the correct display of the website pages may be blocked completely.
    6. We will retain cookie files for a maximum period of 12 months from the date of collection. Please refer to our partners’ privacy policies for more information on our partners’ cookie retention period.
    7. We use the following types of cookies:
      • ID cookies: cookies remembering an anonymous identifier that we have assigned to the user
      • Technical cookies: these are cookies that are saved when our partner is allowed to set their own cookie on our coverage.
  4. Opting out
    1. User may prevent data collection, processing and its transmission to third parties by downloading and storing a following cookie from Cookie Market in his or her web browser. If the user is using more than one web browser or more than one computer system, a cookie must be downloaded and stored in each of the browsers. Clearing a browser’s cache from cookies will require re-downloading of an opt-out cookie.
    2. User may also disable cookies and local storage in his/her web browser. However, it may impact web browsing experience, as many websites are using cookies to store user’s preferences.
  5. Users rights
    1. Users are entitled to:
      • the right to access data and receive a copy thereof, i.e. obtain information whether we process user’s personal data and specific information about such processing;
      • the right to rectify (amend) their data;
      • the right to delete data, restrict the processing of data, provided that a relevant ground for such action apply;
      • the right to object to data processing;
      • the right to data transfer, i.e. receive data we were provided with in a structured, commonly used and machine-readable format and if necessary, to request transmitting those data to another controller;
      • the right to complain to a supervisory authority;
      • and the right to withdraw consent.
    2. If a user considers that our processing of his or her information infringes data protection laws, this user has a legal right to lodge a complaint with a supervisory authority responsible for data protection. This may be done so in the EU member state of user’s habitual residence, his or hers place of work or the place of where the alleged infringement took place.
    3. Where the legal basis for our processing of user’s information is consent, user has the right to withdraw that consent at any time. However, withdrawal will not affect the lawfulness of processing done before the withdrawal.
    4. The above described rights may be exercised by providing us with a written notice to the address specified in section 1 above.
  6. Data transfers
    1. Should the relationship with one of our clients or partners involve cross-border data flows outside the European Union, our partner is formally obliged to undertake to comply with the best data protection standards set out by GDPR.
  7. Data retention period
    1. If we are the data processor of personal data, such data shall not be kept for longer than specified by the data controller.
    2. If we are the data controller of your personal data, we will retain your personal data for a minimum period of 12 months following your subscription.
    3. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation.
    4. Usage data are not personal data and may be stored up to 24 months.
  8. Miscellaneous
    1. This policy may be updated from time to time by publishing a latest version on our website. A new policy shall be consider binding immediately after its publication on the website.
    2. We will inform you of any such changes via email notification or notification on our website, if possible.