financeAds International GmbH (“financeAds” or “We”) is committed to protecting and respecting your privacy.
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: firstname.lastname@example.org 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:
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:
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.
Our legitimate business interests
Our legitimate interests in collecting and retaining your personal data are described below:
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:
We will use this information:
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:
We will disclose your personal information to third parties:
The lawful basis for the third party processing will include:
Where we store and process your personal data
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 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. 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.
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 email@example.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:
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 and to our DPO on email@example.com
Berlin, 21 May 2018