Platform Privacy Policy
Last updated: 23.07.21
TheViewPoint Media Inc. (“TheViewPoint”, “we”, “us” or “our”), provides an advertising technology that allows our clients, to build, manage, and grow their own ad exchange and earn more money for every ad sold while affording them total control and transparency.
This Privacy Policy for TheViewPoint Services (the “Policy”) explains how we collect, use, and disclose information through our services (the “Services”).
If you are interested in learning how we collect, use, and disclose information through our corporate Website, and learning how to exercise applicable prihttps://theviewpoint.com/vacy rights related to such information, please click here.
We respect your privacy and are committed to protecting it through our compliance with this Policy. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.
ABOUT THE SERVICES
We provide an advertising technology Services. Websites, mobile apps and publishers of other internet-connected digital media properties such as internet-connected TVs (each a “Digital Property” and collectively “Digital Properties”) use the Services to sell ad space on those properties. Advertisers or companies on the advertiser’s behalf, use the Services to purchase that ad space in the most efficient way possible. The Services also allow Digital Properties and advertisers to do other things, like measure the effectiveness of their ads, to help prevent malware or other bad activity, and similar functions designed to make the buying and selling of ad space seamless, efficient, and effective.
OUR PRINCIPLES REGARDING USER PRIVACY AND DATA PROTECTION
- Lawfulness, transparency and fairness;
- Purpose Limitation;
- Data Minimization;
- Accuracy;
- Storage limitation;
- Confidentiality and integrity.
Your privacy and security are of the utmost importance to us. We will always follow these principles
SHORT SUMMARY
| Information we collect and use | The Services are designed to collect and use primarily Services Data and, in some instances, use it together with Other Information (more). |
| How does TheViewPoint collect information | The Services use cookies, beacons, pixels, tags, mobile SDKs, and other non-cookie technologies to collect and store Platform Data about web browsers and devices across websites and apps (more). |
| Purposes for using the collected information | TheViewPoint uses the information collected on the Services to provide, operate, manage, maintain, and enhance the Services and allow our clients to use our Services. This means facilitating: serving of ads, including interest-based advertising by our clients and partners; facilitating serving of ads based on precise geographic location information; reporting on ad delivery and conversions; providing frequency capping and recency measurement; using information for fraud detection and the prevention and detection of malicious behavior and maintaining and enhancing. (more) |
| The information does TheViewPoint share with third parties | Where permitted, we provide clients and their third-party providers access to their Services Data that they collect, acquire, or use on the Services, and typically they may remove it from the Services for their own use. A list of third parties can be viewed here. We may also provide Services Data and Other Information to partners and service providers for the purpose of operating, managing, maintaining, or enhancing our Services, including for the safety and security of the Services and the online industry, or as required by law. |
| Your rights | If you are a resident of certain jurisdictions as EEA or US, you may have certain rights and protections under a particular jurisdiction’s law regarding the collection, processing, and use of information about you. More for EEA residents. More for California residents. |
| Where TheViewPoint is located | We are located in the United States with data centers located in the United States. If you access any of the Digital Properties (as defined below) that use our technology, please be aware that your information may be transferred to, stored and processed by us and our affiliates in our facilities in the United States and by those third parties with whom we may share your information |
| This Policy may be updated by us from time to time. Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendment.The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes. | |
WHAT INFORMATION DO WE COLLECT AND PROCESS
When you as an internet user visit a Digital Property that has integrated our Services or that uses technology that integrates with our Services, we may collect certain information about your visit. This Policy refers to this information as “Services Data”, and includes the following:
| Browser info | the type of browser you use, browser language, browser settings, and cookie information. This may include data about you related to bid requests an ad impression, collected when we decide to show you an ad on a Digital Property and when we deliver an ad. |
| Device info | device IDs (IDFA or AAID), device model, network and device performance, browser type, language, information enabling digital rights management, operating system |
| Location info | when location services have been enabled for an app on your device that has integrated our technology or that may send that information to our Service. |
| Info about your activity on a Digital Property | browsing history, viewing history, search history and information regarding an individual’s interaction with an internet website, app, or advertisement, including the time web pages or apps were visited or used, including in-game or online viewing activity (e.g., videos viewed, pages viewed). |
| Ads info | types of ad, where the ad was served, whether you clicked on it and whether you visited the advertiser’s website or download the advertiser’s app. |
| The information We collect about you does not directly identify you, and we take care to ensure that we do not collect any information that tells us who you are. However, the information listed above could be combined with Other Information to identify or reveal information about you, so it may qualify as personal information or personal data under applicable law. | |
| As described in further detail below, we may collect the categories of personal information listed above from other sources, such as our affiliates. | |
| Our Services allow Digital Properties, advertisers, and others to buy and sell data to help make the ads that you see more relevant. Advertisers may share with us information about your interests or demographic information (your age or gender) that they have collected directly from you and from third parties, and they may use that information on our Services to help make the ads served to you more relevant or for other purposes. | |
SOURCES OF INFORMATION COLLECTED BY THE SERVICE
| Cookies and other online tracking technology | When you first visit a Digital Property, you may be installed a cookie to your browser or device, which allows the Services to automatically recognize your browser or device the next time it visits another Digital Property. his allows our clients and partners to sync their own unique identifiers against this ID so that they can use their own data on the Services that they may have associated with you.The Services may use cookies, beacons, pixels, tags, mobile SDKs, and similar technologies to collect this information. For a detailed description of cookies and similar technologies set by the Services, see the TheViewPoint Cookie Policy. |
| We may collect other information from our affiliates and other companies (“Other Information”). | |
| Other companies: | We may collect information from other companies such as analytics providers, advertising and marketing firms, information suppliers, and other partners. |
HOW DO WE USE YOUR INFORMATION
| Our Services use, and allow our clients to use, the information we collect for the following purposes: | |
| For legitimate interests | For providing Services to advertisers and owners of Digital Properties, including providing and operating our services which includes:
|
| For support purposes | Our staff gives help to clients use the Services, for example by configuring advertising campaigns for clients to best meet their objectives. |
| For the advertising purposes |
|
DISCLOSURE OF YOUR PERSONAL DATA
We may share Services Data for the following categories of recipients and for the following reasons:
| Our clients and third-party providers | When you visit a Digital Property and that Digital Property wants to show you ads, and, in order to show you those ads, the Digital Property may allow certain third parties to access your device or receive and use the information |
| Service providers | We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we’ve hired to provide customer service support, operate the technical infrastructure that we need to provide the Service, assist in protecting and securing our systems and services, and help market own products and services as well as partner products, services, events, and co-branded promotions in which we involved. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity |
| Advertising partners | We work with advertising partners to enable us to customize the advertising content you may receive on our Service. These partners help us deliver more relevant ads and promotional messages to you, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising via the Services. We and our advertising partners may process certain personal data to help TheViewPoint understand your interests or preferences so that we can deliver advertisements that are more relevant to you. |
| Our partners | We may share personal data with that third party about your use of the Services, such as whether and to what extent you have used the offer, activated account, or actively used the Service. Furthermore, we also may share your personal data in a pseudonymised format with our industry partners to help them understand how the content they license to us is performing and to enable you to listen to streaming content via the Service. |
| Affiliates | We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us |
| Law enforcement and data protection authorities | We may share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also may share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data. |
| Business Transfers | We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. |
| Aggregated Data | We may also share aggregated data derived from the Services, including, for example, statistics about Services activity. |
YOUR RIGHTS AND OPTIONS
If you are a resident of certain jurisdictions as EEA or US, you may have certain rights and protections under a particular jurisdiction’s law regarding the collection, processing, and use of information about you.
You have the right to opt-out of marketing emails and other direct marketing (if any);
Access the personal data we hold about you. If you request, we will provide you a copy of your personal data in an electronic format; and
You also have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can withdraw your consent, for example by turning off cookies in your browser settings. We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please let us know. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
All these rights may be fulfilled by you simply emailing us with the relevant request to dpo@theviewpoint.com
Find more details below.
WHAT DATA PROTECTION RIGHTS YOU HAVE UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TheViewPoint aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.
The General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of access – the right to be informed of, and request access to, the personal data we process about you;
- Right to rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to erasure – the right to request that we delete your personal data;
- Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to object – the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
- Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
We will process your requests to us within 30 days. We will also notify a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.
We have assigned a Data Protection Officer (DPO) who may be reached via dpo@theviewpoint.com
However, you can also contact and have the right to lodge a complaint with your local Data Protection Authority.
Additional privacy rights under the California Consumer Privacy Act (CCPA) can be found in California Online Privacy Protection Act Compliance section, which contains supplemental disclosures relating to the processing of your personal data.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
Beginning January 1, 2020, the California Consumer Privacy Act (“CCPA”) gives California residents certain rights with respect to the processing of personal data (known as “personal information” under the CCPA).
This supplement provides additional privacy disclosures and details additional rights and should be read in conjunction with our Privacy Policy.
If you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under Disclosure of Your Personal Data section section.
If you are a California resident and would like to make such a request, please submit your request in writing to us via dpo@theviewpoint.com
If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Personal Information Collected and Processed
Requests to Exercise Your Rights
Disclosures of Personal Information for a Business Purpose
Personal Information Collected and Processed
Our Privacy Policy sets forth the categories of personal information that We collect and processes about you, a description of each category, and the sources from which we obtain each category.
Requests to Exercise Your Rights
RIGHT TO KNOW REQUEST – Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:
- Categories of and specific pieces of personal information we have collected about you;
- Categories of sources from which we collect personal information;
- Purposes for collecting personal information;
- Categories of third parties with which we share personal information;
- Categories of personal information disclosed about you for a business purpose.
If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.
To make a verifiable request for information about the personal information we have collected about you, please to make a request by using the dpo@theviewpoint.com
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
RIGHT TO DELETE REQUEST – You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete emailing to dpo@theviewpoint.com.
HOUSEHOLD REQUESTS – We currently do not collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.
REQUESTS, GENERALLY – Please note, if you do not have a user account we will not have enough information about you to verify your Right to Know and Right to Delete requests, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to the User Service where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.
REQUESTS MADE THROUGH AGENTS – You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Disclosures of Personal Information for a Business Purpose
In the preceding 12 months, We have disclosed certain data from the following categories of personal information to the categories of recipients listed in Section “Disclosure of Your Personal Data” of our Privacy Policy for one or more business purposes:
- None
Sale of Personal Information
We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a “sale” under the CCPA.
While we do not sell any personal information, we do provide Usage Data to advertising partners to enable us to provide you with interest-based advertising. For more information on interest-based advertising, please see our Cookie Policy.
We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.
To exercise these rights, you can contact us by email at dpo@theviewpoint.com. If you have a complaint about how we handle your data, we would like to hear from you.
EU-U.S. PRIVACY SHIELD STATEMENT
TheViewPoint Media Inc. complies with the EU-U.S. Privacy Shield Framework Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield. TheViewPoint Media Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
We have adopted and subscribed to the EU-U.S. Privacy Shield Framework Privacy Shield Framework (collectively, “Privacy Shield”) as part of our efforts to establish and maintain an adequate level of Personal Data privacy protection. We adhere to the Privacy Shield Principles including the Supplemental Principles, (collectively, the “Privacy Shield Principles”) for Personal Data received from entities in the European Economic Area (the “EEA”) and United Kingdom (“UK”).
In addition to the measures provided for by the Privacy Shield we provide adequate safeguards that which in particular include Standard Contractual Clauses approved by EU Commission.
When we receive personal data from the European Economic Area or transfer personal data from the European Economic Area to other countries, we use appropriate legal mechanisms to help ensure all applicable laws, rights and regulations continue to protect your data.
Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses are available here. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
Also, the transfer of personal data is carried out using the protective measures mentioned in the section “How Do We Protect Your Information”.
Our commitments under this policy apply to the processing of Personal Data that TheViewPoint Media Inc. obtains from Customers located in the European Union.
Pursuant to the Privacy Shield Frameworks, EU, UK, individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.Upon request, we will provide you with access to the personal information that we hold about you.You may also correct, amend, or delete the personal information we hold about you.An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query todpo@theviewpoint.com or info@theviewpoint.com.If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.To request to limit the use and disclosure of your personal information, please submit a written request todpo@theviewpoint.com or info@theviewpoint.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
TheViewPoint Media Inc.’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles.In particular,TheViewPoint Media Inc. remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with thePrinciples, unlessTheViewPoint Media Inc.proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, TheViewPoint Media Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and United Kingdom with Privacy Shield inquiries or complaints should first contact TheViewPoint Media Inc. at: dpo@theviewpoint.com or info@theviewpoint.com.
TheViewPoint Media Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, TheViewPoint Media Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
As a last resort and in limited circumstances, EU individuals with unresolved privacy complaints may invoke a binding arbitration option before a Privacy Shield Panel.
OPT OUT OF INTEREST-BASED ADVERTISING
| To learn more about interest-based advertising, please visit the Network Advertising Initiative opt out page, the DAA’s WebChoice tool or the DAAC’s WebChoices tool. | |
| Please note: | |
| Blocked cookies | The opt-out cookie may not work if your browser is configured to block third-party cookies. |
| Deleting opt-outs | If you delete your cookies, you will need to opt out again. There are browser plugins to help you preserve your opt-out cookies |
| Only this browser | The opt-out only applies to the browser profile in which you set it. For example, if you set the opt-out while using Firefox, but then use Chrome, the opt-out will not be active in Chrome. To opt out in Chrome, you will need to repeat the opt-out process. This is because the cookies cannot be read between different browsers or browser profiles. |
| The opt-out does not block or delete cookies | It also does not prevent the use of cookies or other technologies for purposes other than selecting ads based on your interests as inferred by your online behavior. If you opt out, data may still be collected about your web browsing activities, and you will still see advertising. Ads may be selected, for example, based on the content of the web page in which they are shown. If you wish to block or delete cookies altogether, you can use web browser settings to do so. |
| Mobile devices | Mobile device system software such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” on iOS devices). Devices vary in where they include the setting to adjust, you can use the Network Advertising Initiative’s mobile optout guide. |
| TV | Your internet connected device (e.g. a smart TV or a set- top box) may give you the ability to opt-out of the use of information for advertising purposes. To determine if your Internet connected device has these options, please visit your device’s settings menu. |
| Location Data | Most mobile devices offer you the ability to stop the collection of location information at any time by changing the preferences on your device. You may also be able to stop the collection of location information by particular apps by adjusting the settings for individual apps or following the standard uninstall process to remove specific mobile apps from your device. Note when location services have not been enabled in any of your apps, we may still infer data about your location based on your IP address. |
WHERE THEVIEWPOINT IS LOCATED
We are located in the United States with data centers located in the United States. If you access any of the Digital Properties that use our technology, please be aware that your information may be transferred to, stored and processed by us and our affiliates in our facilities in the United States and by those third parties with whom we may share your information.
These countries (including the United States) may not provide an adequate level of data protection for your information (as determined by the European Commission for personal data in its jurisdiction) or have data protection or other laws as comprehensive as those in your country.
HOW DO WE PROTECT YOUR INFORMATION
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process which included:
- using secure shell protocol (SSH);
- multi-factor authentication;
- access control (physical and technical);
- link encryption.
The protection of your personal information is important to us. We maintain appropriate safeguards and current security standards to protect your personal information from unauthorized access, disclosure, or misuse, such as using Secure Socket Layer (SSL) encryption for all supplied sensitive/credit information. However, no system can be completely secure, and we cannot ensure or warrant the security of any information you provide to us. While we take meaningful steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We do not accept liability for unintentional disclosure.
However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through TheViewPoint and/or the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
The Site may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.
Personal information will be pseudonymized and encrypted to ensure the user privacy. The collected information will be handled for standard cases of use described in this Privacy Policy.
DATA TRANSFERS AND INTERNATIONAL DATA TRANSFERS
Our servers are located in the USA. If you are accessing our Site from outside the USA, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in other countries. In such instances TheViewPoint shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place.
TheViewPoint Services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than the United States (or your own country, if you are using Services outside of the United States, despite the geographic restrictions provided in the Terms), we take steps to ensure adequate safeguards are in place to protect your data as explained in this privacy policy.
Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission.
When we transfer personal data from the European Economic Area to other countries, we use appropriate legal mechanisms to help ensure all applicable laws, rights and regulations continue to protect your data.
Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses are available here. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
CHANGE OF OWNERSHIP OR BUSINESS TRANSITION
In the event of a change of ownership or other business transition, such as a merger, acquisition or sale of our assets, your information may be transferred in accordance with applicable privacy laws.
DATA RETENTION
We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
We process and for about 6 months store the pseudonymized data on the cloud servers with all necessary means and measures of data protection, let alone special requirement provided by GDPR (fraud, legal claim, etc.). Other than that, all personal data is deleted once the 6-month period is over.
Services Data is usually aggregated or deleted within 6-month period but may be retained in the Services longer for specific clients and for security and the detection and prevention of fraud and invalid traffic from the date of collection before aggregation or deletion. When we no longer need the information we collect, it is deleted or aggregated. Aggregated information is used for reporting and analysis and may be stored in the Services for up to 2 additional years.
When partners receive information through us or clients remove their information from the Services, their storage and retention of the removed information is governed by their own privacy policies and applicable laws, rules, or regulations.
CHANGES TO THE POLICY
This Policy may be updated by us from time to time. Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendment.
The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.
TERMS OF SERVICE
Please also visit our Terms of Use which state the terms, disclaimers, and limitations of liability governing your use of the Site and Services.
CONTACT US
If you have any questions or suggestions regarding our Privacy Policy, please contact us at info@theviewpoint.com
If you have any requests for resolving issues (other than issues related to data protection) we encourage you to contact us through dpo@theviewpoint.com or info@theviewpoint.com
If you are a resident in the European Economic Area, the “data controller” of your personal information is TheViewPoint Media Inc., with the address at 79 Madison Ave, New York City, New York 10016, USA.