The website adsheavy.com and the services made available by it is provided by RED KEY SERVICES LTD., an United Kingdom company (“Company”, “AdsHeavy”, or “AdHeavy”). We take the protection of your information seriously. This Privacy Policy (the “Policy”) explains how we collect your and your End Users information and how we use it. Together with our Terms of Use, it governs your use of the Service.

1. Which Information We Collect?

We may collect two types of data and information from our Users:

• • Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Site. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site, type of operating system, User’s ‘click-stream’ or searches on the Site, type and version of browser, keyboard language, screen resolution, etc.
  • Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
    Users of the Site automatically provide their IP address mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.
    When opening an Account, you may be required to provide the following details: full name, e-mail address and a password. Once your contact details received by us, our representative will contact you to complete the registration process. Our representative may collect additional information from you.
    In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User (e.g. in the contact or payment-details forms on the Site) or during the business cooperation.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists. We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the TOU and the Privacy Policy.

2. How Do We Collect Information on Our Users?

We receive data from the computer, mobile phone or other device used to access the Service. This may include IP address, the type of browser, system and language, date and time of visits, the type of internet service, location (including GPS location when made available to us), the pages visited, and the way of interaction with ads and other types of content.

• • “Cookies” – data files, which often include a unique identifier, sent to an internet browser or application and placed on a computer or mobile device in order to store certain information. We may use both session cookies (which expire once the web browser is shut down) and persistent cookies (which stay on the device until deleted). Some of the content included in the Service may contain and send cookies to your computer or mobile device. Usually you can set your web browser to refuse all cookies or to indicate when a cookie is being received; this may, however, interfere with the use of the Service by you. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, refer to your browser’s help section. We also use Google Analytics, Mixpanel, Hot Jar and other similar products to obtain anonymous aggregated usage data. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
  • “Beacons” or “Pixels” – electronic files used to track your navigation through the Service, email messages sent to you, the completion of transactions, submittal of applications and browsing behavior. You may be able to opt-out of beacon tracking by adjusting the settings on your browser.
  • “Log Files” – when you use the Service we may track and record actions occurring on the Service and collect certain technical data including your IP address, browser type, internet service provider, referring/exit pages, platform type, date/time stamp, click data and types of advertisements viewed.
    
  • Information which you decide to provide us voluntarily. For example, we collect Personal information when you contact us through the contact form or when you open an Account.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below

3. How We Generally Use the Information

We use the information we collect to provide you with the Service, to maximize the relevancy and quality of the Service. For example:

• • Provide and personalize content of the Service to our users;
  • Monitor and improve the effectiveness of the Service;
  • Monitor aggregate metrics and statistical information regarding the Service and the users thereof;
  • Enhance the User’s experience while using the Site and Services.
  • Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of our Site’s Users as well as in order to safeguard our Site.

4. Sharing Information with Third Parties

AdsHeavy will not share any Personal Information it collects with any third party, other than in the following circumstances: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (e) to protect the rights, property, or personal safety of the Company, its Users or the general public; (f) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of the Company, so long as such acquirer maintains the same privacy terms hereunder; or (g) pursuant to your explicit approval prior to the disclosure. Note, that we collect, hold and/or manage Personal Information through AdsHeavy’s authorized third party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. For avoidance of doubt, AdsHeavy may transfer and disclose Non-personal Information to third parties at its discretion, including without limitation for statistical, analytical and research purposes and for customization, development and improvement of our Site and Service.

AdsHeavy collects following information by using tags, user agents and cookies in order to optimize and provide the qualitative work of processes.

5. Privacy Policy with respect to your End-Users

In order to provide you with our Services and serve Ads to your Properties, and in order to constantly improve our Services, we and our authorized third party advertisers may collect, use and disclose certain data related to the end-users of your Properties (the “End-User Data” and the “End Users“, respectively).

End User Data consists of the following types of information:

• • End-Users Non-personal Information: Non-personal Information is any unconcealed information which does not enable identification of an individual End-User. Non-personal Information is available to us and may be available to our authorized third party advertisers while End-Users are accessing or using your Properties. Non-personal Information which is being gathered may consist of technical information, behavioral information or aggregated information, and may contain, among other things: technical data, e.g. type of operating system and configuration, screen resolution, screen density, software version, hardware type, usage patterns and other statistical data, the time the End-Users were engaged with the Ads on your Properties, etc.
  • End-Users Personal Information: We and our authorized third party advertisers may collect the following Personal Information: End-User’s IP address, Device ID, geo-location (country, region, city) and/or other behavioral information related to a particular End-User. It should be noted, however, that such information is not used by us in order to personally identify a specific End-User but rather for technical and statistical purposes, as described below.

Collection. We and our authorized third party advertisers may collect End-User Data if you provide it to us and/or once you serve Ads (and/or Ad serving scripts) to your Properties. The End-User Data may be collected by the use of various tracking technologies. We and our authorized third party advertisers may gather, collect and store the information either independently or through the help of our authorized third-party service providers as detailed below.

Purpose. We and our authorized third party advertisers may use the End-User Data in order to provide you the Services, i.e., for the purpose of displaying Ads of our third party advertisers on your Properties. For example, we will collect Personal Information in order to determine geo-location information from which the End-User is connected to the Internet in order to serve Ads through the Service based on such End User’s location. In addition, we and our authorized third party advertisers will collect End-User Data in order to (i) create statistics and other aggregate information and analysis with respect to your End User’s engagement with Ads which are served to the Properties through the Service; (ii) use it for statistical, analytical and research purposes and for customization, developing and improvement of our Services; (iii) for general campaign performance in order to report to our authorized advertisers or SSPs; (iv) to determine the amounts to bid, pay or offer for impressions or units of ad-inventory; and/or (v) detect fraudulent activities that occur while your End Users are engaging with Ads on your Properties.

Third Parties. In addition to the sharing of End Users Data in order to fulfill the purposes mentioned above, we may share your End User’s Personal Information in the cases specified in Section 4 above.

Deletion or Modification of End User Data. Since we have no direct relationship with your individual End-Users and we do not send communications to your End-Users, you hereby agree to handle all End-User’s requests with respect to deletion and modifications of their information. End-Users who seek access to their Personal Information, or who wish to correct, amend, delete inaccurate information or withdraw consent for further use of their Personal Information should direct their request to you. If you are unable to handle such a request and only we possess the ability or power to solve your End-User’s request or issue, please forward that request to us and provide us with the necessary instructions and we will make reasonable efforts to solve the issue pursuant to any applicable privacy laws. Unless you instruct us otherwise, we may retain your End-Users’ Personal Information for as long as reasonably required for the purposes for which such Personal Information was collected, all as permitted under any applicable privacy laws. Aggregated and/or anonymous data may remain on our servers indefinitely.

Children/Minors End User Data. You agree that you will not use the Services in connection with any Properties directed to Minors. The term “Minor” shall mean a Child as such term is defined under the Children’s Online Privacy Protection Act of 1998 and the rules promulgated by the Federal Trade Commission (FTC) under that Act, including but not limited to the Children’s Online Privacy Protection Rule 16 C.F.R. Part 312 (the “COPPA“) or any other under-age individual as defined by applicable children protection legislation in any relevant jurisdiction. You will (i) notify AdsHeavy in writing of any Properties which are or may be considered as a “Child Property” under the COPPA, and (ii) to the extent required by applicable laws, implement reasonable commercial means within the Properties for identifying Minors when the Properties are not primarily directed at children under such age; all in order to enable AdsHeavy to block collection of information from Minors. If you learn that any information transferred to us via the Services includes Personal Information collected from Minors, please inform us immediately and we will delete that information as quickly as possible.

Tracking Technologies with respect to End Users. When Ads (and/or Ad serving scripts) are served to your Properties via the Services, AdsHeavy and/or third party advertisers or SSPs may use industry-wide tracking technologies (e.g., cookies, web beacons, etc.) which store certain information on the Properties (“Technologies“) and which allow us or such third parties to collect certain data for the purpose of serving Ads through the use of our Services (including without limitation, serving Ads that may be of interest to End Users). As above stated, AdsHeavy will not use the Technologies in order to personally identify a specific End User. In each case, End Users will be subject to the third party advertisers’ privacy policies.

Behavioral Advertising. You should notify your End Users that our authorized third party advertisers may serve you behavioral advertisements. You should include a conspicuous mechanism by which your End Users may opt out of such online behavioral advertising.

6. Cookies

When Customer uses and accesses the Website, AdsHeavy may place a number of cookies files in Customer’s web browser.

AdsHeavy uses cookies for the following purposes:

• • To log into your account.
  • To distinguish between unique web browsers, and to store data for advertising purposes, including interest-based advertising.
  • To store ad delivery and reporting data for clients, such as, for example, which ad was shown, the number of times a particular ad has been shown, and how recently an ad was shown to a particular web browser.
  • Cookies play a role in cross-device linking where cookies from different browsers or devices might be associated with each other.
  • AdsHeavy Products uses cookies to analyze user behavior when we add new features or some changes.
  • Some browsers or other software may be configured to block third party cookies by default.

7. Children’s Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register to the Service. If you are under 13, please do not use the Service and do not send any information about yourself to us. No one under the age of 13 is allowed to provide any personal information to us. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us promptly at [email protected].

8. Opt Out

In any event, if for any reason you (or any person) wish to delete or modify Personal Information, please send us an e-mail with adequate detail of your request to: [email protected] and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws. Aggregated and/or anonymous information derived from your use of the Site or Services may remain on our servers indefinitely.

9. Security

We use industry standard measures to ensure the security of all information, including the use of passwords, firewalls, encryption and remote servers, and routinely evaluate our practices to identify security threats or opportunities for the improvement of our Service. However, no transmission of the information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise information security. You acknowledge and agree to assume this risk when communicating with us.

10. International Data Transfer

In order to provide the Site and Service, we may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

11. Changes to This Privacy Policy

By using the Service, you consent to our collection and use of your personal information as described in this Policy. If we make material changes to this Policy, we will notify you by placing a post regarding those changes on the website of the Service or by other means, as per our sole discretion. We reserve the right to modify this Policy at any time, so please review it frequently. Changes to this Policy are binding and effective when they are posted on this page. To the extent that the Service has your e-mail address on record, we may use this to inform you of changes to this Policy.

12. Data Protection Officer

AdsHeavy Company appointed Data Protection Officer in connection with GDPR adoption. Customer can contact him in case he has any questions at info@adsheavy.com or at the address below.