This Privacy Policy Addendum is provided to help end users understand how Clickky collects and processes their data.

This Privacy Policy is substitute to our General Privacy policy, which is applicable to all users (including our corporate clients) and may be found here – https://clickky.biz/privacy-policy/

If you won’t find some information you think should be inhere, please read carefully our General Privacy Policy.

1.Information We Collect and Process Through our Services (PII NPII)

1.1. Personally identifiable informю/ation

We do not collect, store, process or disclose any of Personally identifiable information (“PII”) that directly identifies an individual by our tracking technology, such as name, surname, email address, address, telephone number.

However, when our ad appears on a website or app through our basic trafficking tracking system (https://www.cpactions.com), we may collect data which according to some data protection laws (e.g. General Data Protection Regulation) can be classified as PII, such as (where applicable) IP-address or we may receive IP-address, location, Identifier for Advertising (ios – idfa, android – google id) through bid requests from our supply partners.

We may collect such data on legitimate basis, whenever it is necessary to secure our transactions (e.g. determine fraudulent activity of our partners), provide our services accurately, make our software work accurately for best user experience or when we are required by law to collect such data (if applicable).

1.2. Non-Personally Identifiable Information

“NPII” is data that cannot be used on its own to identify or trace a person.

Rarely from supply side partners we may receive the following personal data:
– gender
– year of birth
– interest segments

Whenever such information is combined with PII, we treat such received information as Personal Data.

How we process personal data European Economic Area (EEA) or Swiss individuals

If we receive from our supply partner the confirmation that an end user provided a compliant consent to collect, store and process the user’s personal data, the aforementioned data is collected fully, otherwise, we do:
– IP anonymization by replacing the last octet of the IP with a “0” (e.g. 123.123.123.123 → 123.123.123.0)
– Blanking identifiers for Advertising (idfa/gaid), location, gender, year of birth and any other personal data sent, either intentionally or accidentally with an empty string.

Moreover, we would like to share instructions of how to opt out for mobile devices:

Android Users (version 2.3 and above) – opt-out of interest-based advertising

iOS users (version 6 and above) – limit ad-tracking

Purpose of Collecting Data

We use the information we collect and receive from our partners to display relevant ads, which might be interesting for you.

In addition, we use the information to detect fraudulent activity.

– Share

We may share your PII in the following cases:

1) to perform services on our behalf we share PII with publishers, advertisers, developers or other 3rd parties.

2) when we are obligated by law to disclose your information

3) to prevent fraud by transferring NPII to a third-party fraud monitoring system.

In cases we share data with counterparts from non-EEA countries (if they were not acknowledged as «providing necessary level of data protection»), we do it by using relevant data protection agreements (as a way of example, but no limited to: Standard Contractual Clauses adopted by EU Commission).

– Data Security and Retention

Information that we collect is stored using procedures reasonably designed to help protect information from unauthorized access, modification, or disclosure.

We may keep the information relating to your device for a period up to 3 months. Reports generated from the collected information may be kept longer, as necessary for internal analytical purposes.

– Children’s Privacy

We do not knowingly collect and store information about users under the age of 18 without prior parental consent or consistent with applicable law.

We do not manage any campaigns which target ads at children under the age of 18 without prior parental consent or consistent with applicable law.

– Your rights

You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address provided in this Privacy Policy or through the opt out form: see what Personal Data we have about you, if any; change/correct any Personal Data we have about you; have us delete (right to be forgotten) or transfer (export) Personal Data we have about you; to know where your Personal Data is stored and processed (if processed by third party/parties – right to know name and location of the processor/processors); express any concern you have about our use of your Personal Data (including objecting against the processor); withdraw your consent for our collection, processing and use of your Personal Data; other rights granted to you by relevant data protection laws. As well you can submit claim to relevant data protection body, if you will think we haven’t responded to your request properly.

– Contact us

If you have any requests or questions regarding our collection and use of information, you may contact us by emailing at privacy@clickky.me