Privacy Policy

 

financeAds International GmbH (“financeAds” or “We”) is committed to protecting and respecting your privacy.

 

This Privacy Policy (together with our General Business Terms and Conditions for Affiliates and General Terms and Conditions for Advertisers and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new 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 strict framework within which commercial organisations can legally operate.

Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force, the data controller is financeAds International GmbH, registered at Amtsgericht Charlottenburg (Berlin) with register No.: HRB 164756 B with its registered address at Hardenbergstrasse  32, 10623 – Berlin, Germany.

According to § 37 General Data Protection Regulation (GDPR), we have nominated ePrivacy GmbH represented by Prof. Dr. Christoph Bauer with its registered address at Große Bleichen 21 - 20354 Hamburg, Germany, email: privacy@eprivacy.eu as our external company data protection officer (DPO).

 

 

Who we are and what we do

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 the personal data of the following types of people to allow us to undertake our business:

  • Prospective and existing advertisers and publishers (together “clients”) contacts;
  • Supplier contacts to support our services;
  • Employees.

We collect information about you to carry out our core business and ancillary activities.

 

 

The information you give to us or we collect about you 

This is information about you and your business that you give us by filling in forms on our site (an example is this form: www.financeads.com/uk-en/publishers/signup/  (“our site” or “our website”) 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 name, address, both private and/or corporate, e-mail address and phone number, fax number, link to your corporate website and / or advertising space, visits per month of that given advertising space, page impression per month of that advertising space, sales region.

 

 

The information we collect about you when you visit our website 

With 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;

 

 

The information we obtain from other sources 

This is information we obtain about you from other sources such as LinkedIn, corporate websites, your business card.

We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, and professional advisors. We may receive information about you from them for the purposes of our services and ancillary support services.

We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out below (depending on the types of information we receive).

 

Purposes of the processing and the legal basis for the processing 

We use information held about you in the following ways:

  • To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your organisation.
  • To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.

 

The core service we offer to our advertisers and publishers is the introduction of one to the other 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 business interests, described in more detail below, although we will 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 organisation or any other contract to provide services to you or receive services from you or your organisation (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.

 

 

Our legitimate business 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 initiate a partnership where publishers will run advertising campaigns on the advertiser’s behalf. The exchange of personal data of our publishers to the 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.
  • To maintain, expand and develop our business we need to record the personal data of both publishers and advertisers.
  • To deliver our ancillary services we need to contact clients on a regular basis, through various routes such as email, phone, newsletters and other relevant notifications.

 

 

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, 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 to this particular processing at any time.

Other uses we will make of your data:

  • use of 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.

 

We will use this information:

  • 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.

 

 

Cookies 

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

 

 

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. financeAds International GmbH may share your personal data only if you have given your informed consent for us to do so.

We will share your personal information with:

Selected third parties including:

  • Advertisers for the purpose of introducing them to publishers;
  • Publishers for the purpose of introducing them to advertisers;
  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
  • subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your business where this is a condition of us entering into a contract with you.

 

We will disclose your personal information to third parties:

  • 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.

 

The lawful basis for the third party processing will include:

  • Their own legitimate business 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;
  • for the purpose of a contract in place;
  • to fulfil their legal obligations.

 

 

Where we store and process your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our services. By submitting your personal data, you agree to this transfer, storing or processing. financeAds International GmbH will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

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.

 

 

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, upon GDPR legislation on the 25th May 2018 we will have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

  • 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.

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:

  • the nature of the personal data;
  • its perceived accuracy;
  • our legal obligations;

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. 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 on to 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.

 

 

Your rights 

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

You can exercise the right at any time by contacting us at privacy@financeads.com

Our site may, from time to time, contain 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 websites 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.

 

 

The GDPR provides you with the following rights to:

  • Request correction  of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you, corrected.
  • Request erasure  of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing  of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing  of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer  of your personal information to another party in certain formats, if practicable.

 

 

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 privacy@financeads.com  and to our DPO on privacy@eprivacy.eu

 

 

Changes to our Privacy Policy 

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

 

 

Contact 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@financeads.com and to our DPO on privacy@eprivacy.eu

 

 

Berlin, 21 May 2018 

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