financeAds International GmbH (“financeAds” or “We”) is committed to protecting and respecting your privacy.
The General Data Protection Regulation (EU) 2016/679 (GDPR) is a regulation which replaces the Data Protection Directive (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a regulatory environment within which international business operate.
For the purposes of data protection legislation in force, the data controller is financeAds International GmbH, registered at the Chamber of Commerce of Charlottenburg (Berlin) with register No.: HRB 164756 B with its registered address at Hardenbergstrasse 32, 10623 – Berlin, Germany, represented by its Managing Director Alvise Perissinotto
According to § 37 General Data Protection Regulation (GDPR), we have nominated as our External Data Protection Officer (DPO):
For all requests concerning the security of your data, please contact our data protection officer at firstname.lastname@example.org
1. Who we are and what we do
https://www.financeads.com/ is a site operated by financeAds International GmbH ("financeAds"). We are a marketing agency business helping banks, insurance and Fintech companies (“advertisers”) to acquire new customers for their online products through a network of highly relevant online publishers (“publishers”) that promote the advertisers` product through advertising material uploaded by advertisers to our platform. We also provide the following other services: consultancy, media planning and creative creation. We collect personal data of the following categories of data subjects to allow us to carry out our core business and ancillary activities:
- Exsisting customers
- Potential customers
- Subscribers to our Newletters
- Potential employees
2. The information you give to us or we collect about youThis is information about you and your business that you give us by filling in forms on our site (or “our website”) (an example is this form: www.financeads.com/uk-en/publishers/signup/) or by corresponding with us by phone, e-mail or otherwise.
It includes information you provide when you register to use our site, enter our database (by submitting an application form and/or a contact form and/or subscribing to our newsletter and/or signing a contract with us), subscribe to our services, attend our events, or other social media functions on our site, and when you report a problem with our site/service.
The information you give us or we collect about you may include your contact information, both private e/o corporate, account information, visits per month, page impressions per month and sales region.
3. The information we collect about you when you visit our websiteWith regard to each of your visits to our site we will automatically collect the following information: technical information, including browser type and version, browser plug-in types and versions, the time zone setting, operating system and platform; no IP address is collected.
4. Purposes of the processing and the legal basis for the processing
The core service we offer to our advertisers and publishers is the introduction of one another for the purpose of temporary or permanent engagement. However, our service expands to supporting clients with their marketing strategies.
Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although we also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into an agreement with you or your business or any other contract to provide services to you or receive services from you or your business (examples of when consent may be the contract basis for processing include permission to introduce a publisher to an advertiser and vice-versa).
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.
5. Our legitimate interests
Our legitimate interests in collecting and retaining your personal data are described below:
- As an affiliate network we introduce publishers to an advertiser expecting them to enter into a partnership where publishers run advertising campaigns on behalf of the advertiser. The exchange of personal data of our publishers to advertisers and vice-versa is a fundamental, essential part of this process.
- In order to support and suggest new advertising campaigns to our publishers or to suggest new publishers to our advertisers, we require a database of clients` data containing historical information as well as current requirements and advertising material.
- provide our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Potential customers
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If financeAds International GmbH or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our General Business Terms and Conditions for Affiliates and General Terms and Conditions for Advertisers and other agreements; or to protect the rights, property, or safety of financeAds International GmbH, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- their own legitimate interests in processing your personal data, in most cases to fulfil their internal resourcing needs; satisfaction of their contractual obligations to us as our data processor;
- satisfaction of their contractual obligations to us as our data processor;
- purpose of a contract in place;
- to fulfil their legal obligations.
- We keep in touch with you so you can let us know of changes to your personal data
- Our newsletter subscription form enables you to unsubscribe anytime
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- to request Information about the processing of your data free of charge, as well as the receipt of a copy of your personal data. You can request information on the purposes of the processing, the categories of personal data (If they are passed on), the duration of the storage or the criteria for determining the duration;
- to correct your data. Should your personal data be Incomplete, you have the right to complete the date, taking into account the processing purposes;
- to delete or block your data. Reasons for the existence of a cancellation/blocking right can be, among others, the revocation of the consent on which the processing Is based, the data subject objects to the processing, the personal data were processed unlawfully;
- to restrict the processing;
- to object the processing of your data;
- to revoke your consent to the processing of your data in the future, and
- to complain to the competent supervisory authority about inadmissible data processing.
To maintain, expand and develop our business we need to record the personal data of both publishers and advertisers.
Should we want or need to rely on consent to lawfully process your data we will request your consent verbally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent at any time.
Other uses we will make of your data:
We will use this information:
We use functional cookies that are strictly necessary for the website to work and cannot be switched off in our systems. We use them to make sure our digital services work correctly; some essential features on our website just won’t work without these cookies. The functional cookies allow our website to remember choices you make to give you better functionality and features.
8. Disclosure of your information inside and outside of the EEA
financeAds International GmbH will not sell, lease, rent or otherwise disclose your personal data unless you have given explicit consent.
We will share your personal information:
Selected third parties including:
We will disclose your personal information to third parties:
The legal basis for third party processing will include:
9. Where we store and process your personal data
As a safety measures third parties outside the EEA participate in the U.S.-EU Privacy Shield Framework , in the EU Standard Contractual Clauses and in the California Consumer Privacy Act disclosures to meet the adequacy and security requirements of the European Union's General Data Protection Regulation (GDPR).
All information you provide to us is stored on secure servers managed by us or on our behalf by our third-party partners. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. Retention of data
We understand our legal duty to retain accurate personal data and only retain data for as long as we need it for our legitimate interests and that you are happy for us to do so. Accordingly, and based on the General Data Protection Regulation (GDPR) we will have a data retention notice and run data routines checks to remove data we no longer have a legitimate interest in maintaining.
We do the following to try to ensure our data is accurate:
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our Customer Relationship Manager (CRM) system, our platform and third-party tools. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data onto our database, unless requested to do so.
For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
11. Your rights
You have the right to ask us not to process your personal data for marketing purposes. Before collecting your data, we will inform you if we intend to use your data and/or if we intend to disclose your information to any third party for such purposes. We will collect express consent from you, if legally required prior to using your personal data for marketing purposes.
You can exercise your right at any time by contacting us at email@example.com
Our site may, from time to time, contains links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. The GDPR provides you with the following rights
You have the right - partly under certain conditions:
13. Access to information
The GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
A subject access request should be submitted to firstname.lastname@example.org
Berlin, last update on 6th January 2020