I. GENERAL INFORMATION

I.1. As a platform for user acquisition solutions and traffic monetization, including through self-serve platforms (“Services”), Сlickky Group Limited (“Clickky”, “we”, “us”) respects personal data privacy of the publishers, advertisers, and other users of the Clickky’s website at clickky.biz (“Users”, “you” and “Website” respectively).

I.2. Clickky is committed to complying with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance and Directive 95/46/EC. For those reasons, Сlickky provides this Privacy Policy Statement (“Policy”), which explains how, when, and for what purposes Clickky collects and uses the information about the Users that specifically identifies them and the information about their activities during the Services provision, when directly linked to personally identifiable information (“Personal Data”).

I.3. This Policy does not cover the collection and use of your Personal Data by our business partners (counterparties), and does not cover any information that may relate to Clickky outside of the Website and self-serving platforms.

I.4. This Policy shall be considered the integral part of the terms and conditions (agreement) between you and Clickky, together with the terms and conditions for the Self-serve platform for Advertisers and Self-Serve platform for Publishers.

I.5. By using our Services, you consent to this Policy. We also inform the Users about the terms of collection of the Personal Data on or before such collection. For the purposes of Personal Data (Privacy) Ordinance and the guidelines issued by the Office of the Privacy Commissioner for Personal Data (Hong-Kong), this Policy contains all the provisions required for the Personal Information Collection Statement (“PICS”). Thus, the Users shall provide their active consent on the collection of the Personal Data on or before such collection under the terms hereof.

I.6. Clickky reserves the right to amend this Policy at any time and indicate the date of the last amendments on the top in the “Last amended” field. The User’s continued use of the Services after any such amendments and notification thereof (which may be sent via e-mail to the address provided in the course of the User’s creating the account) shall constitute the User’s consent to and acceptance of such amendments.

I.7. Please pay attention that this Policy does not protect information you post to any online profile, bulletin board, electronic communication, chat room, or any other publicly accessible forum independent of Clickky.

II. COLLECTION OF THE PERSONAL DATA

II.1. We collect the Personal Data that you input into our Services and the data automatically generated by your use of our Services. 

II.2. You may input the Personal Data to make use of certain features of our Services. For example, when you create your account, you may be required to enter the Personal Data about yourself such as: name, e-mail, skype, telephone (identifying information). You may also be required to provide corporate information (company’s name, company’s e-mail, website) and financial information (billing information, credit card number, expiration dates, and security codes, which are transferred to a third-party provider of payment services and is not retained by Clickky).

II.3. We also collect certain basic information to provide better services to the Users based on the inventory we have an access to, including:

II.3.1. Through our basic trafficking tracking system, which gathers IP addresses, UserAgent and whether or not the user has our domain cookies (https://www.cpactions.com);

II.3.2. Via our publishers which may provide us with user device information (hardware model, unique device identifier, OS version, device language), user age, user gender, and device permissions. In such cases, Clickky does not collect information associated with the publishers’ user’s personal information, such as name, phone number, address, or any kind of the information that can identify such user as a person.

II.4. As to the cookies, the User shall understand the following:

II.4.1. Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalization. It can include pieces of data embedded in an image on a website or email that allow for tracking of your activity on a website or your actions with regard to an e-mail, such as whether you opened the e-mail or accessed a link within the e-mail, etc.

II.4.2. The categories of cookies we use are:

– Strictly necessary cookies – enable you to move around the Services; for example, help to remember you are logged into your account;

– Performance cookies – collect anonymous information about how you use the Services to enable us to improve how they operate;

– Functionality cookies – allow us to remember your user name, language, and the region you are located or other information to provide you with an experience more appropriate with your selections;

– Targeting and advertising cookies – allows us to collect information about your browsing habits and deliver advertisements that are more relevant to your interests. That information is shared with other parties such as advertisers.

II.4.3. You shall specifically agree to our use of cookies when you use our Website by clicking the respective button in the notification. 

II.4.4. Generally, internet browsers contain controls for managing cookies. Those controls may enable you to delete cookies or to accept or reject certain categories of cookies. If you reject or delete cookies, the performance of the related features and functions of our Website or Services may be impaired to you.

III. PURPOSES OF THE COLLECTION

III.1. Clickky collects and uses your Personal Data for the following purposes:

– proper provision of the Services to the Users;

– creation and maintenance of your account;

– processing of your inquiries and operations at the Services;

– analyzing and understanding our audience for the purposes of improving our service; improving of delivery optimization, content selection, and other parts of the Services;

– communicating with you concerning our Services;

– assist third parties acting on our behalf;

– ensure a smooth transition of the Services in the event of a merger, acquisition, reorganization, sale of all or substantially all of its assets, or sale of one of our User’s website;

– investigate and/or enforce violations of our terms and conditions and/or this Policy, or to protect our interests in our operation and our legal rights and protections;

– other purposes.

III.2. We may directly communicate with the Users through e-mail, instant messages, and/or telephone provided to Clickky to ensure the proper Services provision and to promote our Services. Notices by Clickky may be given either by electronic messages to your registered e-mail address or by a general posting to your home page.

III.3. We use the information indicated in paragraphs 2.3 and 2.4 hereof for certain purposes, including managing our business and improving our Services and ensuring the proper work of our Services. For instance, as to the platform for publishers, since our aim is to find relevant users for the products and services we promote and to improve the user experience of the advertising inventory for which we are distributing, we are trying not to disturb the user flow or user experience with the ad the user sees if said user has no desire to be engaged with the service that was offered. We use the user IP-range to define their location and country in order to distribute relative ads. We may also target users based on other criteria such as aforementioned criteria: user device, OS, language, UDID, and hardware model.

IV. TRANSFER AND DISCLOSURE OF THE PERSONAL DATA

IV.1. We do not sell, share, or allow access to any of your Personal Data to the third parties, except as provided herein.

IV.2. We may need to send the information to third parties (our employees or third party companies), who work on our behalf, to provide a product or service to you within the Services provision under our terms and conditions. In cases where we need to disclose or share your Personal Data with such third parties, any such use of your Personal Data will be limited to the information required in that individual case.

IV.3. We may hire other companies to perform certain business related functions such as processing payments on our behalf. Our payment processing partner may request that you provide certain personal data (e.g., a valid government issued ID, your legal name, address, and date of birth) for the purpose of making payment through its financial institutions and complying with any federal and state laws and regulations. They may also communicate directly with you regarding any issues with a payment. Any information provided to our third party will be confidential and only be used for intended purposes.

IV.4. Clickky (including our affiliates, advertisers, and content providers) independently reserves the right to fully cooperate with requests from any recognized law enforcement or governmental authority, and to court orders, requesting or directing Clickky (including our affiliates, advertisers, and content providers) or from any third party entities investigating complaints related to bulk electronic communication complaints (SPAM, SPIM) requesting Clickky (including our affiliates, advertisers, and content providers) to disclose the identity or other information regarding any person who is or was using our Services. By accepting our Terms and Conditions and this Policy, you waive and hold Clickky (including our affiliates, advertisers, and content providers) harmless from any and all claims resulting from any and all actions taken by any of the foregoing during or as a result of any law enforcement or governmental authority’s investigations or inquiries.

V. ACCESS TO THE PERSONAL DATA

V.1. The Users have the right to request access to and correction of their Personal Data, including the right to obtain a copy of their Personal Data provided to Clickky.

V.2. The Users may modify or remove any of their Personal Data associated with their account at any time by logging into their accounts and accessing the respective Personal Data features, or by contacting a representative of Clickky, as set out in Section VII hereof, to keep the respective Personal Data accurate and up-to- date.

V.3. Clickky will maintain User’s records (identifiable information and any transactional or payment information) in accordance with applicable laws and regulations, but no longer than it is necessary for the Services provision and other purposes indicated herein.

VI. SECURITY

VI.1. We believe we use reasonable administrative, logical, physical, and managerial measures to safeguard your Personal Data against loss, theft, and unauthorized access, use, and modification.

VI.2. Your accounts are secured by your personal user name and password. We use reasonable measures to protect information that is stored within our database, and we restrict access to such information to those employees who need access to perform their job functions (i.e., account representatives, financial services staff, and senior management).

VI.3. However, we cannot assure you that Personal Data will never be used or disclosed in a manner that is inconsistent with this Policy. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of such Personal Data at any time. You should understand that no feasible system of data security is invulnerable. Accordingly, we cannot guarantee the 100% security of your information.

VII. GEOGRAPHY

VII.1. We store your Personal Data in the European Union (“EU“). Any Personal Data gathered by Clickky in connection with our Services may be transferred to, processed, and stored in countries where data protection laws may be less protective than the legislation where you live. This may happen when facilities belonging to Clickky are located in a country outside of the European Economic Area or in a country which is not the party to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (1981).

VII.2. Supplying Clickky with the Personal Data, you permit its transfer outside the country within the bounds of such use. When a transfer to non-European countries happens, we ensure that it takes place in accordance with this Policy and applicable laws.

VIII. ENQUIRIES

VIII.1. Any enquiries regarding the Personal Data provided, including the requests for access to, correction, or removal of your Personal Data, should be addressed to e-mail at support@clickky.me.