Privacy Policy

CTVBuyer values your privacy and, therefore, has set up this privacy policy to inform you about its data processing practices and your rights.

Please read this privacy policy carefully. If, after reading it, you have any questions, please contact CTVBuyer for further clarifications.

1. General

1.1 Applicability and responsible entity. This privacy policy applies to the processing of personal data collected through the Websites https://CTVBuyer.com and http://app.CTVBuyer.com (collectively, the “Websites“) owned and operated by CTVBuyer LLC having a registered business address at 3422 Old Capitol Trail #670, Wilmington, DE 19808, the United States of America (“CTVBuyer“) and the digital advertising monetization services provided by CTVBuyer (the “CTVBuyer Services“). This privacy policy does not cover any third-party websites, software products or services.

1.2 CTVBuyer as a data controller and data processor. When handling personal data, CTVBuyer acts as a data controller and a data processor in terms of the applicable data protection laws, including, the EU General Data Protection Regulation (GDPR). The role of CTVBuyer depends on the specific situation in which personal data is collected and used as explained in detail below:

CTVBuyer as a data controller. CTVBuyer acts in the capacity of a data controller when it asks you to submit your personal data that is necessary to ensure your direct access and use of the Websites and the CTVBuyer Services (e.g., when you conclude a service contract, browse the Websites, or communicate with us). In such instances, CTVBuyer makes decisions about the types of personal data to be collected and the purposes for which such personal data should be used. CTVBuyer complies with data controller’s obligations set forth in the applicable laws.
CTVBuyer as a data processor. CTVBuyer acts in the capacity of a data processor in situations when, within the scope of the CTVBuyer Services, publishers and other CTVBuyer clients (collectively, the “Clients”) submit personal data to CTVBuyer for processing (the “Clients’ Data”). CTVBuyer does not own, control, or make decisions about the Client’s Data. CTVBuyer processes the Client’s Data only in accordance with the instructions provided by the respective Clients. The Clients submitting the Client’s Data usually act as data controllers and they are responsible for deciding what personal data should be collected from data subjects and how such data should be processed by CTVBuyer. To ensure that the Client’s Data is processed in accordance with the strictest data protection standards, CTVBuyer has drafted and offers a data processing agreement that is available for consultation at https://CTVBuyer.com/data_processing_agreement http://app.CTVBuyer.com

1.3 Children. The Websites and the CTVBuyer Services are not marketed to and should not be accessed and used by persons under the age of 18. Therefore, CTVBuyer does not collect personal data from persons under the age of 18.

1.4 Term and termination. This privacy policy enters into force on the date specified at the top of the privacy policy and continues in effect until updated or terminated by CTVBuyer.

1.5 Amendments. If CTVBuyer decides to amend this privacy policy in order to address changes in its business practices, laws, regulations, or industry standards, this page will be amended and, if your contact details are known by CTVBuyer, you will receive a notice about the amendments. CTVBuyer will specify the date of last amendment at the top of the privacy policy. CTVBuyer encourages you to review then-current privacy policy from time to time to stay informed.

1.6 Your consent. Taking into account that CTVBuyer relies on the legal bases for the processing of your personal data other than your consent (section 2 provides more information), you do not have to consent to this privacy policy. Nevertheless, CTVBuyer may seek your specific and informed consent if:

CTVBuyer decides to collect personal data that is not mentioned in this privacy policy;
Your personal data needs to be used for purposes that are not indicated in this privacy policy;
Your personal data needs to be disclosed or transferred to third parties that are not specified in this privacy policy; or
Your consent is required under the applicable law.

1.7 Cookies. The Websites uses cookies. Some of the CTVBuyer Services are also based on cookies. Cookies may be considered to be personal data (e.g., when they allow tracking you and customising the Websites accordingly). In the CTVBuyer cookie policy available at https://CTVBuyer.com/cookie-policy/ it is explained in detail what types of cookies CTVBuyer uses, for what purposes they are used, and how you can control your cookies.

1.8 Third-party links. The Websites may contain links to other websites or services. Please be aware that CTVBuyer is not responsible for the privacy practices of those third-party websites and services. For security purposes, you should always consult the privacy notices of any third-party websites, software, or service that you access.

2. Types and purposes of personal data collected by CTVBuyer

1.1 Applicability and responsible entity. This privacy policy applies to the processing of personal data collected through the Websites and (collectively, the “Websites”) owned and operated by CTVBuyer LLC having a registered business address at 3422 Old Capitol Trail #670, Wilmington, DE 19808, the United States of America (“CTVBuyer”) and the digital advertising monetization services provided by CTVBuyer (the “CTVBuyer Services”). This privacy policy does not cover any third-party websites, software products or services.

CTVBuyer as a data controller. CTVBuyer acts in the capacity of a data controller when it asks you to submit your personal data that is necessary to ensure your direct access and use of the Websites and the CTVBuyer Services (e.g., when you conclude a service contract, browse the Websites, or communicate with us). In such instances, CTVBuyer makes decisions about the types of personal data to be collected and the purposes for which such personal data should be used. CTVBuyer complies with data controller’s obligations set forth in the applicable laws.
CTVBuyer as a data processor. CTVBuyer acts in the capacity of a data processor in situations when, within the scope of the CTVBuyer Services, publishers and other CTVBuyer clients (collectively, the “Clients”) submit personal data to CTVBuyer for processing (the “Clients’ Data”). CTVBuyer does not own, control, or make decisions about the Client’s Data. CTVBuyer processes the Client’s Data only in accordance with the instructions provided by the respective Clients. The Clients submitting the Client’s Data usually act as data controllers and they are responsible for deciding what personal data should be collected from data subjects and how such data should be processed by CTVBuyer. To ensure that the Client’s Data is processed in accordance with the strictest data protection standards, CTVBuyer has drafted and offers a data processing agreement that is available for consultation at https://CTVBuyer.com/data_processing_agreement/.http://app.CTVBuyer.com/

1.4 Term and termination. This privacy policy enters into force on the date specified at the top of the privacy policy and continues in effect until updated or terminated by CTVBuyer.

CTVBuyer decides to collect personal data that is not mentioned in this privacy policy;
Your personal data needs to be used for purposes that are not indicated in this privacy policy;
Your personal data needs to be disclosed or transferred to third parties that are not specified in this privacy policy; or
Your consent is required under the applicable law.

2. Types and purposes of personal data collected by CTVBuyer

When you use the Websites and the CTVBuyer Services, CTVBuyer collects some data from you, both personal and non-personal as described in detail below. CTVBuyer complies with data minimisation principles and, therefore, collects only a minimal amount of personal data that is necessary to ensure your use of the Websites and the CTVBuyer Services. Your personal data is used only for specific purposes for which it is requested. CTVBuyer does not re-purpose your personal data without your prior consent. Below, you can find a detailed list of all personal data that CTVBuyer collects from you, the purposes for which your personal data is used, and the legal bases on which CTVBuyer relies when processing your personal data.

2.1 Personal data collected when you signup. When you signup on the Websites, CTVBuyer collects your (i) full name, (ii) email address, and (iii) website address. Such personal data is used to:

Verify, create, and maintain your user account;
Provide you with the requested services;
Contact you, if necessary;
Send updates;
Analyze CTVBuyer business; and
Send promotional materials (subject to your prior consent).

The legal bases that CTVBuyer relies upon when processing your personal data are:

Performing a contract with you;
Pursuing its legitimate business interests (i.e., to analyze and improve its business); and
Your consent (for promotional materials).

2.2 Personal data collected when you update your user account. When you update your user account, CTVBuyer collects your (i) address, (ii) billing address, and (iii) phone number. Such personal data is used to:

Update your user account;
Provide you with the requested services; and
Analyze CTVBuyer business.

The legal bases that CTVBuyer relies upon when processing your personal data are:

Performing a contract with you;
Pursuing its legitimate business interests (i.e., to analyze and improve its business); and
Your consent (for optional personal data).

2.3 Personal data collected when you order the CTVBuyer Services. When you place an order for the CTVBuyer Services, CTVBuyer collects your (i) full name, (ii) billing address, (iii) phone number, (iv) Websites address, (v) email addresses. Such personal data is used to:

Provide you with the requested services;
Contact you, if necessary;
Process your payments;
Maintain CTVBuyer business records; and
Analyze CTVBuyer business.

The legal bases that CTVBuyer relies upon when processing your personal data are:

Performing a contract with you; and
Pursuing its legitimate business interests (i.e., to administer, analyze and improve CTVBuyer business).

2.4 Personal data collected when you request a free site audit. When you request a free site audit through the Websites, CTVBuyer collects your (i) first name, (ii) last name, (iii) email address, (iv) phone number, (v) Websites address, (vi) company name, and (viii) any information that you decide to provide in your message. Such personal data is used to:

Provide you with the requested services;
Contact you;
Maintain CTVBuyer business records; and
Analyse CTVBuyer business.

2.5 Personal data collected when you browse the Websites. When you browse the Websites, CTVBuyer or its third-party analytics service providers collect your IP address and cookie-related data. Such data is used to conduct analytics about your use of the Websites, analyze the content available on the Websites, and prevent abuse of the Websites. The lawful basis that CTVBuyer relies upon when processing your IP address is pursuing its legitimate business interests (i.e., to analyze and improve its business and ensure security). The cookie-related data and its purposes are explained in CTVBuyer cookie policy available at https://CTVBuyer.com/cookie-policy/.

2.6 Personal data collected when you contact CTVBuyer. When you contact CTVBuyer by email, CTVBuyer collects your (i) name, (ii) email address, and (iii) any information that you, at your own discretion, decide to provide in your message. When you leave a message in the chat available on the Websites, CTVBuyer collects any information that you decide to provide in your message. Such data is used to respond to your message. The legal basis that CTVBuyer relies upon is pursuing its legitimate business interests (i.e., to grow the business); if you provide optional personal data, the legal basis is your consent.

2.7 Personal data collected when you leave a comment. When you submit a comment on a blog post available on the Websites, CTVBuyer collects your (i) name, (ii) email address, and (iii) any information that you, at your own discretion, decide to provide in your comment. Please note that the submission of comments is entirely optional. The legal basis that CTVBuyer relies upon is your consent.

2.8 Personal data collected when you leave a testimonial. When you agree to submit a testimonial, CTVBuyer collects your (i) name, (ii) company name, (iii) professional position, (iv) photo, and (v) any information that you, at your own discretion, decide to provide in your testimonial. Please note that the submission of testimonials is entirely optional. The legal basis that CTVBuyer relies upon is your consent.

2.9 Sensitive data. CTVBuyer does not collect special categories of personal data (also known as sensitive data), i.e., information about a natural personâ€™s health, opinion about religious and political beliefs, racial origins, membership of a professional or trade association, or information about sexual orientation.

2.10 Your refusal to provide personal data. If you decide not provide CTVBuyer with your personal data when requested, CTVBuyer may not be able to perform the requested operation (e.g., to register your user account, deliver you the requested services, or reply to you) and you may not be able to use the full functionality of the Websites.

2.11 Personal data received from third parties. CTVBuyer may also receive and retain information, including personal data, from third parties, such as its service providers, ad networks and marketing agencies, which all relate to your preferences and your use of different Websites on the Internet. Such personal data will be used to provide the CTVBuyer Services only, as agreed with the respective third party and, in most cases, CTVBuyer will act as a data processor with regard to such personal data.

3. The Clients’ Data processed by CTVBuyer

3.1 Types of the Clients’ Data. When the Clients use the CTVBuyer Services, CTVBuyer processes personal and non-personal data submitted by the Clients to CTVBuyer. Such data may include data subjects’ names, company names, addresses, email addresses, website addresses, geo-location data, IP addresses, cookie-related data, device ID, browser type, operating system, activity logs, browsing history, search history, interest-related data, interactions with other websites, online behaviour data, and other personal data submitted by the Clients to CTVBuyer within the scope of the CTVBuyer Services.

3.2 Purposes of the Clients’ Data. CTVBuyer uses the Clients’ Data to provide the Clients with the requested services. The legal basis that CTVBuyer relies upon when processing the Clients’ Data is performing a contract with the Client. CTVBuyer does not intentionally access, manage, correct, delete, share, disclose or grant rights to the Clients’ Data in any manner if it is not necessary for the provision of the CTVBuyer Services or enforcement of its legal terms. The Clients are solely responsible for the Clients’ Data, including making sure that the Clients’ Data was obtained in a lawful manner. The Clients are not allowed to submit any personal data that was obtained in an unlawful manner (e.g., without consent of a data subject).

4. Non-personal data

4.1 Types of non-personal data. When you browse the Websites, CTVBuyer or its third-party service providers automatically collect information about your activity on the Websites that helps them to analyze the Websites, including:

The type of your computing device;
The type of your operating system;
The type of your browser;
Your scroll depth;
The pages that you view and your time logs;
Web addresses that you access from the Websites;
Information about your screen; and
Your other online behavior data.

4.2 Purposes of non-personal data. The non-personal data listed above is used to assist you in using the Websites (e.g., to avoid re-entering certain data), resolve technical issues, analyze your use of the Websites, personalize your browsing experience, improve the Websites, develop new services, and prevent abuse of the Websites.

4.3 Aggregated and de-identified data. If your non-personal data is combined with your personal data and such combination allows CTVBuyer to identify you as a natural person, CTVBuyer will treat aggregated data as personal data. If your personal data is de-identified, such data will not be personal data and CTVBuyer may use it for any reasonable business purpose.

5. Disclosure of personal data

5.1When your personal data is disclosed. To ensure and facilitate the provision of the Websites and the CTVBuyer Services, CTVBuyer may need to disclose your personal data to its third-party service providers and other third parties mentioned in this section 5. Your personal data will be disclosed to third parties only in circumstances where:

Your personal data is necessary for (i) ensuring the provision of services requested by you, (ii) replying to your inquiries, or (iii) achieving other purposes for which your personal data was provided;
CTVBuyer has obtained your prior informed consent for sharing your personal data with third parties. Such consent will be requested for any purpose that is not directly connected with providing the Websites and the CTVBuyer Services; or
CTVBuyer has a good reason to believe that your personal data is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process, enforceable governmental or regulatory request; (ii) enforce CTVBuyer legal terms; (iii) detect, prevent, or otherwise address fraud, security or technical issues; or (iv) protect CTVBuyer or your rights, property or safety, as required or permitted by law.

5.2 List of third parties that access your personal data. The third parties that CTVBuyer cooperates with to ensure and facilitate the provision of the Websites and the CTVBuyer Services (i.e., its data processors) agree to ensure an adequate level of protection for your personal data that is consistent with this privacy policy and the applicable data protection laws. CTVBuyer data processors include the following entities:

Email service provider G Suite located in the United States (https://gsuite.google.com);
Cloud storage service provider Amazon Web Services located in the United States (https://aws.amazon.com);
Web analytics service provider Google Analytics located in the United States (https://analytics.google.com); and
CTVBuyer independent contractors and consultants.

5.3 Advertising networks. The Clients’ Data is shared with advertising networks that deliver interest-based advertising based on data subjects’ cookies. The list of advertising networks is kept up-to-date and available for consultation at https://iabeurope.eu/vendor-list-tcf-v2-0 . Data subjects can control how advertisements are shown to them or opt-out from targeted advertising by consulting the guide powered by the Digital Advertising Alliance available at https://yourad- choices.com. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org.

5.4 Merger and acquisition. In the event of merger or acquisition, CTVBuyer may need to share and transfer your personal data to the new business entity (or the new combined entity), which will be required to follow this privacy policy with respect to your personal data.

5.5 Disclosures required by law. If CTVBuyer receives a request from a public authority, it may disclose information about you, including your personal data, if such a disclosure is necessary for pursuing a public interest objective, such as national security or law enforcement.

6. Security

6.1 Security measures. CTVBuyer implements industry-appropriate organizational and technical information security measures to protect your personal data from loss, misuse, unauthorized access, and disclosure, including: (i) secured networks (SSL encryption); (ii) strong passwords; (iii) limited access to your personal data by its staff; (iv) firewalls; and (v) anonymization of personal data (when possible). In order to ensure the security of your personal data, you should use the Websites and the CTVBuyer Services through a secure network only.

6.2 Security breaches. CTVBuyer puts its best efforts to protect your personal data. However, it cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond its reasonable control. In case a serious breach occurs, CTVBuyer will take reasonable measures to mitigate the breach, as required by the applicable law. CTVBuyer liability for any security breach will be limited to the highest extent permitted by the applicable law.

7. International transfers

7.1 Transfers. If it is necessary for the provision and facilitation of the Websites or the CTVBuyer Services, your personal data may be transferred to third parties located outside the country where you reside. For example, if you reside in the country belonging to the European Economic Area (EEA), CTVBuyer will transfer your personal data to jurisdictions outside the EEA (e.g., to the United States).

7.2 Safeguards. When a transfer of your personal data is necessary, CTVBuyer implements the necessary safeguards to ensure that the transferred personal data is properly protected. For example, CTVBuyer will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for personal data, the recipient is a Privacy-Shield certified entity, or an agreement is concluded with a respective third party that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).

8. Retention period

8.1 Retention of personal data. Your personal data is stored in CTVBuyer databases only as long as it is necessary for the purposes described in this privacy policy or until you request CTVBuyer to delete your personal data. After your personal data becomes no longer necessary for its purposes and there is no other lawful basis for storing it, CTVBuyer will make sure to immediately securely delete such personal data.

8.2 Retention of non-personal data. CTVBuyer may retain non-personal data (e.g., technical data collected from you or de-identified data) for as long as necessary for the purposes described in this privacy policy, including for the time period needed for it to pursue legitimate business interests.

8.3 Retention as required by law. In certain cases prescribed by law, CTVBuyer is obliged to store your personal data for a limited period of time (e.g., for accounting purposes or for archiving business records). In such cases, your personal data will be stored for the time period stipulated by the applicable law and deleted as soon as the required retention period expires.

9. Data subjects’ rights

9.1 List of your rights. You, as a data subject, have certain rights to control how your personal data is used by CTVBuyer. Unless there are any exemptions provided by the applicable law, you have the right to ask CTVBuyer to:

Get a list of your personal data that CTVBuyer stores;
Get information about the purposes for which your personal data is collected and used;
Rectify inaccurate personal data;
Move your personal data to another processor;
Delete your personal data;
Object and restrict processing of your personal data (e.g., for marketing purposes);
Withdraw your consent, if you have previously provided it; or
Process your complaint regarding your personal data.

9.2 Exercising your rights. Some of the rights above (e.g., rectification or deletion of your personal data) can be exercised through your user account on the Websites. You merely need to edit or delete personal data that you do not wish to share. To exercise other rights, you can contact us by email at info@CTVBuyer.com and explain your request in detail. You may be asked to provide an identifying piece of information for verification purposes. Your request will be answered within a reasonable timeframe but no later than 30 calendar days.

9.3 Lodging a complaint. If you have any concerns about the way in which CTVBuyer handles your personal data, please contact CTVBuyer first. After receiving your complaint, CTVBuyer will investigate it and provide you with its response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

9.4 Requests regarding the Clients’ Data. When CTVBuyer acts in the capacity of a data processor with regard to the Clients’ Data, it does not accommodate requests related to the access, rectification, deletion, or other rights with regard to the personal data in the Clients’ Data. The persons that would like to exercise their rights with regard to the personal data processed by CTVBuyer should contact the respective Client that acts as a data controller with regard to that personal data. In case CTVBuyer receives a request related to the Clients’ Data directly from a data subject, it will not take action and inform the respective data controller without undue delay.

10. Contact

CTVBuyer wishes to make its privacy practices clear and easy to understand. If you have any questions or concerns regarding this privacy policy or your personal data, please contact CTVBuyer by using the following contact details:

Email: info@CTVBuyer.com

Postal address: CTVBuyer LLC, 3303 South County Trail, East Greenwich RR