Kebijakan Privasi

This Privacy Notice (this “Notice”) describes how your personal information is collected, used, and shared when you visit our website available at https://www.mgid.com (the “Site”), purchase Services on the Site, as defined in our Terms of Service, or otherwise interact with the Site.

The Site is operated by MGID Group together with its Affiliates (“we”, “our”, “us”). With respect to the personal data collected on the Site, we act as a data controller.

We kindly ask you to read this Notice carefully before using the Site and providing us with any personal data. In this Notice “personal data” and “personal information” are used as synonyms.

If you want to explore your opt-out options and use our opt-out tool, then please click here. To use AdChoices opt-out tool, choose your jurisdiction: the U.S., Canada, or Europe (including the UK).

MGID is a member of IAB’s Transparency and Concent Framework 2.0. You may find MGID in the Vendor List under number 358.

MGID participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). You can check our participation status in the Data Privacy Framework List.

Policy Navigation

Section 1. Contact Information

Section 2: Personal Information We Collect

Section 2.1. Website Data

Section 2.1.1. Automatically-collected data

Section 2.1.2. Events and webinars data

Section 2.1.3. Contact data

Section 2.1.4. Subscription data

Section 2.2. Dashboard Data

Section 2.2.1 Registration Data (advertiser)

Section 2.2.2 Registration data (publisher)

Section 2.2.3 Advertisers’ Fund Data

Section 2.2.4 Publishers’ Fund Data

Section 2.2.5 Usage Data

Section 2.3 Widget Data

Section 2.4 Advertising Campaign Data

Section 2.5. Ad Serving Data

Section 2.5.1 MGID as DSP

Section 2.5.2. MGID as SSP

Section 2.5.3. Click Data

Section 2.6. Verification Data

Section 3: How We Share Your Personal Data

Section 4: Your Rights

Section 5: Personal Information of Minors

Section 6: Data Retention

Section 1: Contact Information

Data controller

EU representative

MGID has appointed a European Union representative as required by Article 27 of the GDPR. The EU representative acts as our contact point for supervisory authorities and data subjects located in the EU.

Data protection officer

MGID has appointed an external Data Protection Officer (DPO) to ensure that we comply with the applicable data protection legislation, including the General Data Protection Regulation (GDPR).

Please contact us or our DPO regarding any data protection-related questions. Please note that we may record any communication related to data subject rights to preserve the evidence of the existence of your request and our response.

Section 2: Personal Information We Collect

We may collect and process your personal information when you:

• access and browse the Website (“Website Data”);
• create an account and use our service dashboard (“Dashboard Data”);
• create a Widget (“Widget Data”);
• create and run an advertising campaign (“Advertising Campaign Data”);
• participate in the bidding process (“Ad Serving Data”);
• send us a message via the website form available at https://www.mgid.com/contacts.

If you want to learn more about the processing of your data after you encounter an ad served by us: MGID may also collect personal data through cookies and similar technologies when you are interacting with MGID’s properties that appear on our customer’s websites and other digital properties. Cookies do not collect your email addresses or names. It is our customers’ (the website or application owners) responsibility to ensure that they’ve obtained your consent prior to placing of these cookies and technologies: you may use a cookie consent tool on the website you’re browsing to disable the collection and processing of your data. If you want to learn more about your data collected while you are browsing third-party websites with MGID-powered advertisements on them, please read Sections about Widget Data, Advertising Campaign Data, and Ad Serving Data.

We will process your personal data based on the legal basis that is best suited to achieve the purpose and protect your rights.

The above personal data is collected and processed as follows:

Section 2.1. Website Data

While making a purchase on the Site you provide us with the personal information required to purchase and use the Services, safely surf the Website, subscribe to receive marketing emails, register for events and webinars, or contact customer support. The following subcategories of personal and non-personal information are processed by MGID:

Automatically-collected data;

Events and webinars data;

Contact data;

Subscription data.

When you access and browse the Website, we may collect the following information:

Automatically-collected data

• Users’ device information, operating system information, IP address information, and accessed web pages (including page URL). We collect this information based on our legitimate interest to operate, maintain, and provide you with the features and functionality of the Service. This information will help us to allow you to use the service’s functionality.
• Log files (including the following information: Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information), search queries from which users are directed to a page, navigation from page to page through the MGID services, the domain name of users' Internet Service Provider. We process this information for technical maintenance and security purposes. Moreover, the information is used to improve the Service, ensure its stability, and enable you to use the Service. The legal basis for such processing is our legitimate interest to analyze how the Service is used, diagnosing service or technical problems, or maintaining security.
• Location information extracted from your first IP address numbers is processed to improve your user experience by making a personalised interface. The processing is based on our legitimate interest to personalise your user experience.

Without this information, we will not be able to provide you with smooth and uninterrupted Site operation. Moreover, certain services may be unavailable for you.

Events and webinars data

MGID may from time to time conduct events or webinars. To participate in such events you will be required to provide the following information:

• First name, last name, email address, website URL, phone number, and status (advertisers, publishers, agency, affiliate, product owner, other). We process this information to register you for events and/or webinars based on the contract with you (i.e. acceptance of our Terms of Services).

Without this information, we will not be able to register you for an event or webinar held by MGID.

Contact Data

When you contact us via the Site or contact details available on the Site, you may provide us with the following data:

• Name, email address, IP address, and location data is processed to address you correctly based on contract (when we use yout data to answer to questions arised in the result of your service-related experience), legal obligation (where your request is based on the law, and we are compelled by the law to answer the request or provide information requested), or our legitimate interest to assist you with your inquiry.
• Other personal information that (a) users/customers chose to provide or (b) is necessary for resolving the requested issue. We process this information to assist users with their inquiries related to such personal information based on your consent (where you request to investigate the issue).

Without this information we will not be able to address your issue, answer your request, contact you back, or address you properly, where and as applicable depending on the type of personal information.

On the Website, you may subscribe to receive emails from us with news and updates about the Website and our services. By providing your email in the respective field of the Website, you provide your consent to receive emails from us and our affiliates (meaning companies that control, are under common control with, or are controlled by us). Your data will be processed as follows:

• Full name and email address will be used to send you promotional messages based on your consent.

Without this information, we will not be able to able to send you our promotional offers.

For marketing purposes, we may also refer to the Site Data collected from analytical technologies described in detail in the Cookie Notice.

You may withdraw your consent at any time by contacting us or via the “Unsubscribe” link contained in a marketing email.

When you unsubscribe from receiving marketing emails, your Subscription Data will be erased from the respective database.

Dashboard Data

You may create and use your personal dashboard for multiple purposes, including running advertising campaigns, paying for services, or receiving campaign profits. Categories of personal data collected include:

2.2.1. Registration Data (advertiser);

2.2.2. Registration data (publisher);

2.2.3. Advertisers’ Fund Data;

2.2.4. Publishers’ Fund Data;

2.2.5. Usage Data.

In order to use the functionality of the dashboard, you need to create an account within the dashboard. For this purpose, we collect certain personal and non-personal information from you.

Registration Data (advertiser)

The following personal and non-personal data is required to create an account in the dashboard for advertisers:

• Name, email address, phone number, messaging application, messenger username (messenger ID), user status (affiliate, agency, product owner, brand, local business), and website URL are collected for various purposes, including advertiser’s dashboard account registration, enabling you to use the services by identifying you as our client, and granting you the access to the ad campaigns. We collect this information based on the contract with you.
• Internal User ID is collected for technical purposes. The Service IT system automatically assigns each user with an identification number (ID). The user ID number is used only for the internal purposes of the Service. Such a user ID number is technically necessary to operate the Service, and our processing of this data is based on the contract with you.

We may also use this data for the following purposes:

• provide you with our service: to enable you use the services by identifying you as our client, keeping the status of your subscription, and granting you the access to the ad campaigns;
• inform you of our updates, offer you an opportunity that might be interesting for you, or notify you of events affecting your service: we will use the registration data to offer you the products or services that we think may interest you, to respond to your inquiries, requests, or complaints, or to inform you about product updates, news, best practices, and other helpful or interesting information that can enhance your use of our services;
• marketing: we may send you newsletters, special offers, and promotions, and use this data for other marketing, advertising, and promotional purposes, including general updates, to extent and in cases when such marketing outreach is justified by our legitimate interest.

Registration Data (publisher)

The following personal data is required to create an account in the dashboard for publishers:

• Name, email address, phone number, messaging application, messenger username (messenger ID), user status (affiliate, agency, product owner, brand, local business) are collected for publisher’s dashboard account registration. This information is collected to perform a contract with you.
• Internal User ID is collected for technical purposes. The Service IT system automatically assigns each user with an identification number (ID). The user ID number is used only for the internal purposes of the Service. Such a user ID number is technically necessary to operate the Service, and our processing of this data is based on the contract with you.

We may also use this data for the following purposes:

• provide you with our service: to enable you use the services by identifying you as our client, keeping the status of your subscription, and granting you the access to the ad campaigns;
• inform you of our updates, offer you an opportunity that might be interesting for you, or notify you of events affecting your service: we will use the registration data to offer you the products or services that we think may interest you, to respond to your inquiries, requests, or complaints, or to inform you about product updates, news, best practices, and other helpful or interesting information that can enhance your use of our services;
• marketing: we may send you newsletters, special offers, and promotions, and use this data for other marketing, advertising, and promotional purposes, including general updates, to extent and in cases when such marketing outreach is justified by our legitimate interest.

Please note that without this information you will not be able to register an account with the dashboard and use its functionality.

Advertisers’ Funds Data

In order to run advertising campaigns, an advertiser shall add funds to the dashboard account. For this purpose, we will require the following information:

• Payment sum, payment method (PayPal, Visa/Mastercard/American Express, Capitalist), cardholder`s first name, Cardholder`s last name, Country, State, city, address, postal code, card number, card expiration date, CVV, automatic billing (on/off), automatic billing on (including: card ID, payment system, client ID, currency, card type, expiry date, card first 6 digits, card last 4 digits, when add, when charged), proof of payment are processed to perform contract with advertiser and based on the legal obligation imposed on us. This information will allow us to process payments of users (advertisers). Some of this information is required for accounting purposes.

Without advertiser’s fund data you will not be able to create and run your advertising campaign.

Publisher’s Funds Data

Simultaneously, to receive profits from an advertising campaign running on the publishers’ premises the publisher shall add Publisher’s Fund Data.

The following information will be required:

• PayPal email, Payoneer prepaid card, Bank transfer, including: Transfer Institution, Bank Name, Bank Address, Bank wire/ACH routing number or Bank swift code, Beneficiary's account name, Beneficiary's address, Account number and IBAN (if the bank provides it), country, currency are processed to perform a contract with the publisher and based on the legal obligation imposed on us. This information will allow us to process payments of users (publishers). Some of this information is required for tax, accounting, and anti-money laundering purposes and are thus processed as a legal obligation imposed on MGID.

This information is necessary to receive income from running advertising campaigns.

Usage Data

When you visit the dashboard, we automatically collect certain information about your device or your activities. Personal and non-personal data includes:

• IP Address, web pages viewed (including the URL addresses of such pages), search queries, navigation from page to page, time spent on each page, clicked or selected items, geolocation, messages sent through Service are processed to provide you with better service and based on the legitimate interest to operate, maintain, and provide you with the features and functionality of the Service.

For a detailed description and information about Usage Data please refer to the Cookie Notice

Section 2.3 Widget Data

Each user of MGID services is able to create a content-module, called a widget. For this purpose, MGID will collect the following information:

• Type of widget (smart widget; under article widget; in-article widget; header widget; sidebar widget), sub type (FORMAT: PLUS; FORMAT: MAIN; FORMAT: BLUR), widget name, website, widget title (promoted content; sponsored content; suggested news; you may like; interesting for you; more cool stuff; check this out), infinite scroll (on/off). This data is processed to provide you with more personilized Service, i.e. allow customers to choose desired widget location, desired sub type, to name the widget, allow customers to choose desired website to use Service, choose widget title, enable or disable infinite scroll. We process this information based on our legitimate interest to operate, maintain, and provide our customer with the features and functionality of the Service.
• Internal exchange (on/off) is processed by us to increase the ad’s user engagement. Showing internal links helps to increase page views per visitor ratio, as well as boost time on site. Serving inner recommendations using MGID algorithm helps to increase website user engagement. The legal basis for processing this data is our legitimate interest to operate, maintain, and provide clients with the features and functionality of the Service.
• User shows data, user real shows data, data collected by click-proxy are processed to maintain core Service operations. Such processing is based on the legitimate interest to prove advertising income.

This information is required to provide our customers with access to the features and functionalities of the Services.

Section 2.4 Advertising Campaign Data

Users of MGID’s services could create and run advertising campaigns. This functionality will require the next information (both personal and non-personal):

• Name of an advertisement campaign, Campaign category (automotive; books and literature; business and investing; events and attractions; family and relationships; food and drink; healthy living; home and garden; medical health; personal finance; pets; real estate; shopping; sports; style and fashion; technology and computing; travel; video gaming, Campaign language, Block before show (on/off), Targeting on (includes geolocation; browser; targeting OS; browser language targeting; mobile connection, Audiences, Phone price ranges, Dynamic retargeting, Schedule, Limits (by clicks; select budget; unlimited), Tracking tags, UTM Tagging (may be chose in case customer is using Google Analytics to track the performance utm_content tag value is automatically filled with teaser ID utm_term tag value is automatically filled with widget ID adclid tag will be added automatically as a click ID), UTM Source, UTM Medium, UTM Campaign, Conversation sensors (MGID; Google Tag Manager; Google Analytics). This personal information is processed based on our legitimate interest to operate, maintain, and provide you with the features and functionality of the Service, allow you to customise the Service in a way that will allow to gain better and more targeted results, allow to choose preferred start date of each campaign and choose the budgeting, limit advertisement campaign to time period limits.

We need this information for multiple purposes, including the following:

1. To set a specific name for each advertisement campaign;
2. to choose a specific category of an advertising campaign;
3. to allow you to conduct an advertising campaign using the most suitable language for the respective audience;
4. allow you not to start advertisement campaign straight after creation and moderators' approval;
5. to set specific geolocation, browser, targeting OS, browser language, mobile connection;
6. to set specific targeted audience that already visited advertiser's website;
7. to allow you choose preferable phone price ranges;
8. to allow you set dynamic retargeting;
9. to allow you scheduling respective advertisement campaign;
10. to allow you set daily and total campaign caps;
11. to allow you specify the number of days when ads would not be shown to the user who had an action;
12. to provide you with wider analytical options and increase productivity.

Without this information, you will not be able to create, run and manage your advertising campaign.

Section 2.5. Ad Serving Data

The MGID business model is based on OpenRTB technology allowing pre-determined advertisers to be selected through an auction for each conducted impression. These auctions allow matching deals with advertisers in the most effective way for both parties. These auctions are held programmatically.

Through our widget and digital properties appearing on our customers’ websites, we may provide advertisements to customers’ website visitors based on their recent browsing behavior across different customer websites, browsers, or devices. For example, if a website visitor browses an online shop and look for a new smartphone, then on a subsequent visit to another website they may see advertising content personalized based on their browsing history on the first website (namely, advertisements about smartphones). In order to target advertisements, MGID may use cookies and other technologies.

We may also work with third parties such as ad networks (third parties that display advertisements based on your visits to websites that you have visited in the past), our advertiser customers, and/or traffic measurement services: they may also use cookies and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. However, you should read their privacy policy to learn more about their use of cookies.

Bidding process data includes the following categories of information:

2.5.1 MGID as DSP;

2.5.2. MGID as SSP;

2.5.3. Click Data.

An SSP lets publishers sell their ad inventory across different ad exchanges, while a DSP enables advertisers to buy the required advertising space across several different ad exchanges at the same time. SSPs run a real-time auction and serve the ads.

Conversely, DSPs allow advertisers to leverage audience targeting.

The MGID as DSP requires such personal and non-personal data as:

• Assigned ID, integration ID, SSP cookie "assigned ID", usp String, consent data, user ID, zip code, country, city, time when the ad was demonstrated, IP address, user agent, MGID's id cookie, price to be paid to the SSP, click timestamp are processed to provide you with better Service and allow you receive a detailed invoice. The processing is based on your consent.

The MGID as SSP requires such personal and non-personal data as:

• Assigned ID, integration ID, Consent String, Usp String, User ID, IP address, User Agent, MGID's user ID, DSP's user ID, Gdpr-specific flag, Time when the ad was demonstrated, Visitor's IP, View price to be paid to the MGID, Click timestamp, View price to be paid to the SSP, Antifraud script applied (any available device and data subject data, including plug-in version, type fonts, battery, etc), Information about the click. This information is processed to provide you with better Service and allow you to receive a detailed invoice and is based on your consent.

Without these data, we will not be able to provide you with an accurate and detailed invoice for used services.

We also collect certain information at the moment of the click. This information includes the following:

• IP address, User_id, Referer, Accept_language, Zip code, Country, City, Time, and User_agent are processed for analytical purposes. Moreover, these data allow us to provide you as our client with more personalised services. We may process such data only if you consent to it.
• We grant you the Gdpr-specific flag to mark you as a European resident. This will help us to reduce possible risks related to GDPR accountability. We are processing this information based on our legitimate interest in securely processing your personal information.
• Consent_string data is processed by us to remain certain about your wishes and preferences. This information is processed based on our legitimate interest in securely processing your personal information.

2.6. Verification Data

MGID services allow Clients to monetize their advertising campaigns, and pay for advertising services. MGID uses a third-party verification system UAB “Idenfy” to verify your identity and provide you with paid services.

MGID requires such information as:

• Document issuing country, Verification Status, Client ID, Company name, Document (depending on the issuing country it may be an ID card, passport, driver's license, etc), and Photo. We are processing this information based on legal obligations imposed on us. In particular, the European Union Anti-Money Laundering Directive and the USA Patriot Act, require us to know our customers’ identities.
• Advertiser's name (obtained during the verification). We use the name of the advertiser (and/or the person paying for the advertisement on behalf of the advertiser) and are obliged to disclose it to the ad viewer as required by the Digital Services Act (or DSA), if you register and use our Service as an individual (using personal data of you or the person who authorized you to use their personal data) in the EU or EEA.

This information is required to let our customers use paid Services.

Section 3: How We Share Your Personal Data

We do not sell or lease your personal data. However, we may share your personal data if it is reasonably necessary for the performance of our undertakings with you (such as to process your order) and/or our legitimate interest to maintain and develop the Site. In particular, your personal information may be shared with the following categories of recipients:

1. our affiliates: the names and contact details of our affiliates which may process your personal data in their capacity as data controllers, can be found here;
2. our subcontractors and team members, for example, the support team, technical team, and other team members.;
3. our customers and clients (for example, our programmatic demand and supply partners to serve you with tailored advertisements, publishers and advertisers with the conversion rate-related information based on the analysis of personal data);
4. third-party solutions integrated with the Site, e.g., solutions enabling you add funds to your dashboard account such as PayPal, Visa/Mastercard/American Express, Capitalist (PayPal Privacy Policy https://www.paypal.com/myaccount/privacy/privacyhub; Visa Privacy Policy https://usa.visa.com/legal/global-privacy-notice.html; Mastercard Privacy policy https://www.mastercard.us/en-us/vision/corp-responsibility/commitment-to-privacy/privacy.html; American Express Privacy Policy https://www.americanexpress.com/us/privacy-center/?inav=footer_privacy_statement; Capitalist Privacy Policy https://capitalist.net/privacypolicy;
5. bot traffic prevention solutions such as ReCaptcha powered by Google Inc (Privacy Policy available at ​​https://policies.google.com/privacy?hl=en-US );
6. caching and reverse-proxy load balancing services such as Cloudflare (Privacy Policy available at https://www.cloudflare.com/en-gb/privacypolicy);
7. third-party solutions that provide us with data storage facilities that are physically located in the Netherlands such as Servers.com (Privacy Policy available https://www.servers.com/company/privacy-policy );
8. verification services provided by UAB “Idenfy” (Idenfy Privacy Policy https://www.idenfy.com/privacy-policy/ );
9. government institutions that may request access to your personal data.
10. marketing and customer relationship management services that attract visitors to our website, manage leads and enhance overall customer experience such as HubSpot (Privacy Policy available at https://legal.hubspot.com/privacy-policy).

As required by the applicable laws, we may in some cases be liable for the actions of our subcontractors and other third parties that we may share your data with (for example, data processors and joint controllers under the GDPR and other EU member states laws, service providers and contractors under the CCPA, etc.).

Please note that we and the aforementioned recipients are located in jurisdictions that may not ensure the same level of data protection as the country of your residence. We will endeavor to protect your personal data while it is processed, stored, or transferred.

• We are committed to subject to the U.S.-EU Data Privacy Framework (DPF) Principles, including Swiss-U.S. DPF and UK Extension, all personal data received from the EU, the UK and Switzerland. Where the DPF applies, the Company will be under oversight of the Federal Trade Commission (FTC). You may read the DPF Principles on the U.S. Department of Commerce’s website.
• Standard Contractual Clauses. If and to the extent we are subject to the General Data Protection Regulation, when we transfer personal data to a country that does not ensure the same level of data protection as the country of your residence, we will use additional safeguards, namely, Standard Contractual Clauses (the “SCC”) which are deemed to be appropriate data protection safeguards under the GDPR. The SCCs are designed to ensure that substantially the same level of data protection is ensured by the recipients of the personal data. This includes, for example, strong encryption before transmission, requirements for encryption keys, and encryption of data-at-rest.
• Transfer Impact Assessment. In addition to the SCC, we are conducting regular assessments of the laws and practices of the recipient country. This assessment helps us to verify the security measures and safeguards implemented by that country and recipients of the personal data.
• Security measures (technical and organisational measures). Measures we implement may include pseudonymization of data, encryption, anti-virus software, and access/transfer control requirements. Please note that this is not an exhaustive list of technical or organizational measures we may use, but a general overview.

Section 4: Your Rights

We support the initiative to provide transparency and control over the use of personal data. You may exercise control by letting us know that you no longer want to receive interest-based ads from MGID by opting out (clicking on the opt-out link below, and by exercising your data subject rights.

Opt out from MGID’s interest-based ads

How does opt-out work?

• We use cookies to uniquely identify a browser, which gives advertisers the ability to show targeted ads that are relevant to you. If you would prefer us not to store a unique cookie in your browser, you may opt-out. Note that by opting out, you still may receive advertising from MGID when you visit our websites or websites of third parties where MGID-powered ads appear – it just will not be targeted to you based on your data.
• Our tracking mechanisms operate at the device and browser level, to fully opt out across devices, you may need to do so on each device and browser individually.
• If your browsers are configured to reject cookies, your opt-out may not work, since we identify your choice to opt out based on an opt-out cookie we deliver to you. In this case, you will need to confirm that your browser is configured properly in order for the opt-out to be effective. If you are using a Safari browser on iOS11 or macOS High Sierra, you must first adjust your Privacy and Security Settings to turn off both “Prevent Cross-Site Tracking” and “Block All Cookies”, and then return to this privacy policy or your preferred opt-out platform to reset your opt-out preferences.
• We may use non-cookie technologies in limited cases. Like cookies, these technologies allow us to recommend ads that are tailored to your interests and to remember whether you have chosen to opt out from our services. Please note that some web browsers may not permit you to block the use of non-cookie technologies, but you can do so by simply clicking on the Opt Out feature.

What are the consequences?

• If you decide not to opt out: MGID will serve you personalized recommendations based on your history.
• If you decide to opt-out: MGID will no longer serve you with personalized content recommendations based on your data (such as your Internet use history). You may still receive ads from MGID, but they won’t be using your data to deliver the most suitable content for you.

You may continue to receive advertisements that are selected based on the particular website that you are viewing (such as contextually based ads: the advertisement will be based on the content of the webpage you are viewing, but not your data).

Even if you decide to opt-out on this webpage, you still may receive personalized ads from other advertisers or ad networks. To disable them, you can:

• change your cookie settings on the website where you receive such ads,
• go to the ad network webpage to opt out,
• use the NAI opt-out tool, which will allow you to opt-out of receiving targeted ads from NAI-approved member companies, or
• go to AdChoices and opt-out: the U.S., Canada, or Europe (including the UK).

Exercise your legally protected rights

According to the applicable data protection legislation, you may have the following data protection rights:

1. right to access:

   You are able to request access to your personal data that we store about you. Among others, you may ask us regarding:
   • the purposes for collecting personal information about you;
   • categories of personal information concerned;
   • who receives your personal information or categories of such recipients;
   • how long we are going to store the information about you and if not possible criteria to determine the storage period;
   • when your personal information was obtained not from you directly, the source where it came from;
   • the existence of either profiling activities or automated decision making based on your personal information. Where such activities are performed, we should also inform you about the importance, and expected consequences of them;
   • a copy of your personal information processing. For such requests further, we may charge you with a reasonable fee. We generally provide users with an electronic copy of their personal information unless they request otherwise.

2. right to rectification:

   You have the right to correct inaccurate (for example, old or incorrect) personal information related to you.

3. right to erasure or the right to be forgotten:

   You have, under certain circumstances, the right to request the erasure of your personal information. Please note, that this right only applies to the data available at the time of request and is not applicable to future data.

   Request to the erasure of personal information is possible when:
   • personal information is no longer needed for the purposes it was primarily collected or processed;
   • when you have already withdrawn your consent for processing your personal data, and we do not have other legal ground to process it;
   • when your personal data is processed under legitimate interest and you object to such legal ground. Moreover, there is no overriding legitimate interest to proceed with processing of your personal data;
   • your personal information was unlawfully processed;
   • when your personal data has to be erased due to legal obligation.

4. right to restrict processing:

   You may request us to stop processing your personal information when:
   • you have reasonable doubts that your information is accurate, and we are verifying the accuracy of such information;
   • your personal information was unlawfully processed;
   • the purpose of your personal information collection no longer exists, but you wish to store it longer to defend a legal claim.
   Moreover, you may request us to stop processing your personal data while we are working on a rectification request or request to object to the processing of your personal information.

5. right to data portability:

   You have the right to obtain from us and further reuse your personal data for your own purposes within other services. You will also be able to transfer your personal information from one IT environment to another in a safe and secure way, when certain conditions apply, such as:
   • the processing is based on your consent or needed for the performance of a contract with you;
   • the processing is made only electronically, without any paper-based files included.

6. right to object:

   You have the right to object to the processing of your personal information at any time. This allows you to prevent us from (stop) processing your personal information. This right applies only when one of the following conditions are met:
   • your personal information is used for direct marketing purposes;
   • the processing is based on our legitimate interest;
   • we are performing tasks carried out for the public interest or by governmental authority;
   • your personal information was processed for either research or statistical purposes.

7. right not to be subject to automated decision making and profiling:

   Currently, neither we nor the Website uses your personal data for profiling or decisions made solely by automated means.

8. right to lodge a complaint with a supervisory authority:

   You have a right to lodge a complaint with a data protection authority in a country you either reside, permanently live, work, or in a country where data protection infringement takes place. Please let us know if you have any concerns as to your personal data or our processing of it at dpo@mgid.com. We will do our best to respond to you as quickly as possible given the number of requests we receive at the time you contact us. In any case, we strive to respond to every complaint we receive within one month; however, for EU-U.S. (UK-U.S., Swiss-U.S.) DPF the response time shall not exceed 45 days as required under the DPF Principles.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, MGID commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/file-a-dpf-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

Please note: as required by national laws, we may be legally compelled to disclose your data after receiving a court order, a subpoena or any other official request of a competent public authority (for example, we are subject to the investigatory and enforcement powers of the FTC or any other U.S. authorized statutory body, the EU data protection authorities, the police, etc.), including to meet national security or law enforcement requirements.

You may access, correct, or update the personal data that you have provided to us by either updating the personal data in your account, by emailing your personal account manager, or by emailing us at support@mgid.com.

We may send periodic promotional or informational emails to you. You may unsubscribe from receiving them (opt-out of such communications) by following the opt-out instructions contained in the email (such as clicking the “unsubscribe” link in the footer of the email).

Section 5: Personal Information of Minors

Site is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, or solicit data from children. We do not knowingly process, collect, or use the personal data of children, and in case we receive such data, we will erase it within a reasonable timeframe.

Section 6: Data Retention

As a general rule, we store your data as long as it is necessary for the purposes it was collected and according to the requirements of the applicable legislation. Following the expiration of the storage period, such data will be either erased or anonymised. In particular, your personal data will be processed as follows:

1. Website Data and Automatically-collected Data are stored during the applicable cookie storage period as described in the Cookie Notice. You may also learn more about such data in the Cookie Notice and on the websites of the applicable third parties.
2. Events and Webinars Data, and Contact Data are processed for the period of 1 year following our contact with you.
3. Subscription Data is stored until you remain subscribed to our newsletters.
4. Dashboard Data is stored as long as you have an account with the Dashboard.
5. Widget Data is stored for 1 month, but certain anonymised data may be stored longer (MGID won’t be able to retrieve your personal data back from the anonymised dataset).
6. Advertising Campaign Data is stored as long as you have an account with the Dashboard.
7. Ad Serving Data is usually processed up to 15 months. However, certain anonymised data may be stored longer.
8. MGID as DSP/SSP Data is usually processed up to 15 months. However, certain anonymised data may be stored longer.
9. Click Data is usually stored up to 15 months.
10. Verification Data is usually stored for 8 years.

Personal data is either deleted or anonymized upon the expiry date. After this date, if the data is deleted, your personal data will be made inaccessible and irretrievable for anyone and by no reasonable means. If the data is anonymised, the data will be made impossible to link with you as a natural person.

Section 7: Changes

We keep this Notice under regular review and may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please, review this Notice regularly, or follow the updates on the Site.