INTRODUCTION
MG-Comm EOOD, doing business as MGC (“MGC” or “we”), is a global provider of digital advertising media and data management technology. In our activities we are committed to protecting privacy of individuals (“users”, “you”) and their personal information, therefore we adopted this Privacy Policy (“the Policy”), which is a clear set of rules and provisions we follow in ensuring your personal information is safe and used in strictly in accordance with the applicable laws, such as General Data Protection Regulation EC 2016/679 (GDPR), CCPA, and other applicable guidelines.
We provide a technology platform (“the Platform”) and services which help advertisers reach their audience in an effective way. This technology also delivers a better Internet experience to users by getting access to the content that is most relevant to them. The Platform enables our clients, including advertisers and advertising agencies, to purchase advertising inventory, as well as provides our clients with tools to onboard, segment, activate, and understand their data.
This Policy describes what personal information is collected, how we collect it, what we do with that information, and what controls you have over that information in relation of its use on our Platform.
INFORMATION COLLECTED VIA PLATFORM
1. What Data is Processed on the Platform
MGC collects certain categories of personal data in the course of delivering an ad to you via the Platform, but do not collect directly identifiable data such as your name, home address, phone number, personal ID number, unless you choose to provide such data directly to MGC in relation to special request, inquiry, claim, etc. Instead, MGC collects certain personal data related to your computer or device using cookies and other similar technologies.
With respect to Platform and its services we mostly collect and process personal data that is available to be identified through Google AD-ID identifier (ADID) to your browser and/or device. This identifier allows our Platform to distinguish devices and browsers of different users, and to deliver tailored ads to the user of such browser and/or device.
ADID is a personal data, which in combination with other data obtained when we’re requested to deliver you ads or showing you ads (bid requests and impressions), allows the Platform to collect another group of information, such as:
• imprecise location
• browser type
• operating system
• browser language
• internet service provider.
Our clients may import to the Platform personal data regarding your interactions with them when you visit their websites, mobile apps and other digital content sources, such as:
• time you visited the site
• the page URL
• your IP addresses
• your browser types
• the operating system
• the type of device you used (e.g. laptop or desktop)
• data regarding your activities on the website, app or other digital content source
• other client data, such as user segmentation made by the client.
We may also receive personal data from third-party partners related to the audience segments, personal information that allows them and/or us to associate ADID with those partners’ identifiers, as well as the data that associates your different devices with each other. Such data is also processed on the Platform.
2. How Data is Collected via Platform
MGC uses various technologies to recognize browsers and devices and collect the categories of personal data as described above.
The types of technologies used via the Platform are cookies, device IDs and pixels. Cookies allows us to identify the device or browser. Device ID identifies every individual smartphone or tablet in the world. It is stored on the mobile device and can be retrieved by any app that is downloaded and installed. Pixels allow us, our clients, and partners to understand how users interact with their websites, apps and other resources of digital content.
In the scope as described above, we receive personal data from third parties such as our clients and partners, including ad exchanges (such as Google Ads), publishers (digital content providers), supply-side platforms, audience data partners. We process all this personal data in the Platform.
3. How Data is Used on the Platform
The basic and most important purpose for use of your personal information on our Platform is provision of services to our clients so you can receive tailored advertising based on your needs. This prevents you from getting targeted with the unwanted and/or not relevant digital content on your browsers and devices.
MGC as digital media technology company uses its Platform to process the relevant data to create new products and services for its clients. Also, we strive to provide the best possible services and experience to our clients and users, therefore we constantly improve our Platform by processing the relevant information it contains.
4. Legal Basis for Data Use in the Platform
Our legal basis under the GDPR for processing the data described above may vary depending on personal information concerned and purpose we process it. We strictly adhere to the relevant EU users consent regulations and policies. We collect personal data from you only where the processing is in our (or a third party’s, such as our clients’) legitimate interests and this does not contradict your clearly expressed consents (if applicable) and subsequent choices (such as opt-out). If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate the Platform and show you ads as instructed by our clients. As described before other legitimate interests may include developing our products and services, maintaining and improving Platform.
5. Opt-out
If you want to be excluded from targeted advertising performed by our Platform on behalf of our clients, you can always do so by opting out from further data processing for purposes of delivering ads to you.
Opting-Out from Targeted Advertising and Tracking on Websites
You can opt-out from tracking and targeted advertising using MGC unique cookie identifiers. If you want to be excluded from customized advertising campaigns, please click the button below once and MGC will ensure that no tracking is being applied.
Please note that MGC must set a special anonymous cookie to indicate your decision not to be tracked. Your decision to be excluded from targeted advertising campaigns will remain in effect if this cookie is present in your browser and accessible to MGC.
When you opt out, MGC will collect and store information from your browser or device only as needed to honor your opt-out and for limited research and development purposes to improve our browser- and device-recognition technology, which also helps to improve our ability to honor your opt-out. Please note that if you clear your cookies, or if you use a different browser or device, you will need to renew your opt-out choice.
Cookies are browser and device specific. Opting out from the specific browser and/or device will not affect other browsers and/or devices.
After you opt-out, any data MGC holds will be disassociated from your browser and device and not used for ad targeting anymore. MGC will stop targeting interest-based advertising to that browser. You will still see advertising, which will be less customized to your needs and interests and, therefore, less relevant.
Opting-Out from Targeted Advertising and Tracking in Mobile Applications
For opt-out of ad tracking and targeting on many mobile devices such as iPhones, iPads, Android devices, TV streaming devices, and/or other Smart TV devices or smartphones, you should comply with your device settings and follow instructions provided by the device manufacturer.
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You may also opt-out from interest-based advertising via:
Network Advertising Initiative (NAI) – http://optout.networkadvertising.org/
Digital Advertising Alliance (DAA) – http://optout.aboutads.info/
Digital Advertising Alliance EU (EDAA) – http://www.youronlinechoices.com/
DAA AppChoices page – http://www.aboutads.info/appchoices
When advertising involves the sale of your personal information under the CCPA, you receive ads and offers that are more likely to be useful to you. If you want to stop MGC selling your personal information to advertisers under the CCPA, please take the following step:
• Contact info@mg-comm.com to request erasure of your personal data.
Personal information may be transferred by us to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (EEA) and may be processed by our staff operating outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure that it receives a similar degree of protection.
5. Standard Contractual Clauses and Other Safeguards
We will take all steps reasonably necessary to ensure that all personal information disclosures shall be subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism which may include entering into EC approved standard contractual clauses relevant to transfers of personal information.
We will take all reasonable available measures that the Personal Information shall be used only for purposes consistent with the consent obtained from the user (if applicable).
If the personal information is shared with our clients, partners, vendors or contractors in the US, we will rely on their EU-US Privacy Shield certification for the legitimate use and protection of your private information.
SECURITY
We have appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access and maintain data security of, and to use correctly, the information we collect. These safeguards vary based on the sensitivity of the information that we collect and store. We have implemented procedures designed to limit the dissemination of your information to only such designated staff as are reasonably necessary to carry out the stated purposes as described in this Policy.
We make all reasonable efforts to ensure that any information we possess is accurate, complete, current, and reliable for its intended use. If you have any questions about security on the website or through the Platform, you can contact us at info@mg-comm.com.
RETENTION
We will only keep your information as long as it remains necessary for the identified purpose(s) for which it was originally collected and for up to three (3) years afterwards or otherwise permitted by local laws, or as required for our business operations or by applicable laws.
We may need to retain certain personal information to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes. We may also retain a record of any stated objection by you of processing your personal information for the purpose of ensuring we can continue to respect your wishes.
All retained information will remain subject to the terms of this Policy. If you request that your data be removed from our databases, it may not be possible to completely delete all your information due to technological and legal constraints.
YOUR RIGHTS
According to the applicable laws you may have certain rights with respect to your personal data that we may possess. MGC ensures that your rights related to your personal information are always respected. Following the applicable regulations, guidelines and policies you may exercise the following rights as the data subject:
• Access all the personal information about you held by us. On request, we will provide you with a copy of this information. We reserve the right to charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested. You can exercise your right of access to your personal information:
o By emailing us at info@mg-comm.com; or
o By writing to us at the address below.
• Correct or erase your personal information where appropriate. Please note, you may review and update certain user profile information by logging in, as applicable, to the relevant portions of the Services where such information may be updated
• Restrict the processing of your personal information whilst we investigate your concern
• Where your processing is based on your consent, you have a right to receive your information in a commonly used electronic format or ask we move the data in that format to another provider where your request relates to the data that you gave us direct and where technically possible (data portability); and
• Withdraw your consent at any time when the processing relies upon consent.
CHANGES TO THIS POLICY
MGC reserves the right to change this Policy from time to time. Please check this page periodically for changes. Any such changes will only apply to personal information collected after the revised Policy took effect.
CONTACT US
If you have any questions, comments, or concerns regarding this Data Use Notice or MGC privacy practices, they may be submitted via email to info@mg-comm.com, or in writing by addressing your inquiries to:
MG-Comm
6 Angista Street,
Sofia 1527, Bulgaria
Attn: Data Protection Officer
This Policy was last modified on 18 August, 2020.