Azerion.com Website Privacy Notice

 

Azerion Services B.V. (“Azerion”, “we”, “us” or “our”) respects your privacy and recognizes the importance of providing a secure environment for your personal data. We are committed to being transparent about how we collect and process your personal data. 

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a visitor about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you visit www.azerion.com (“Website”). This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you visit our Website or use any of our other services, all of which together we refer to as “Services”.

In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes within our Services.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

 

1. Who is responsible for processing your Personal Data?

Azerion Services B.V, Boeing Avenue 30, 1119 PE SCHIPHOL-RIJK, Netherlands is responsible (“the data controller”) for the processing of your personal data.

 

2. How do we collect information, and what information do we collect?

When you use our Services, we collect, use, store and transfer different kinds of personal data. As a general principle, we do not collect and do not ask you to provide any “special categories of personal data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The personal data that we collect from or about you falls into the following categories:

 

2.1 Personal Data that you provide to us:

 

When you use our Services, you provide or asked to give us certain information, including:

 

      • Information provided in relation to communication channels: When you contact support by submitting a request or sending an email, we collect information about your role (publisher, advertiser, game developer or others), first and last name, work email, country, and content of your message. If you would like to find out what information you provide to us regarding a specific Service, you can reach us here.

 

2.2 Personal Data that we collect from you automatically:

When you use our Services, we also process device-related information and information about how you interact with our Services, including: 

 

      • Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), device IDs, geolocation data (country based on your IP address), subdomains visited on our Website, browser settings, screen resolution and other technical information.
      • Cookie data: As further described in our Cookie Notice (“Cookie Notice”), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice. 
      • Your usage: We collect information about how you reach and use our Services. Furthermore, we collect information about the websites that led you to our Website. To learn more about which data is processed, please see the section with service specific information below. 

2.3 Personal Data we collect from other third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:

      • Other third parties: We also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to customize certain services and for security purposes.

If you would like to find out what personal data we collect automatically regarding a specific Service, please see the section with service specific information below or you can reach us from here. If you have any questions about how these third parties use your information, we also recommend you to review their policies and contact them directly. Furthermore, you can find the third parties your Personal Data may be shared with by clicking on the following link:

 

 

[Azerion Website Third Party Partners List]

 

3. Do we collect data from minors?

This Website is neither designed nor targeted to minors under the age of 16. We do not knowingly collect any Personal Data on this Website from anyone under the age of 16. In the event that we learn that we have collected personal data from a user under 16 years of age, we will delete that data as quickly as possible. If you believe that a minor has shared personal data with us, please contact our support team through our Website.

 

4. For what purpose do we process your data?

Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

Provision and improvement of our Services

      • to allow you to use our Services
      • to provide support and respond to your requests
      • to identify and correct any bugs/errors
      • to indicate the popularity of our Services
      • to assess the quality of our Services
      • to secure your use of our Services
      • to understand and improve your online experience

Compliance with our legal or regulatory obligations 

      • to determine the legal requirements for processing of your Personal Data (based on your location such as your country) 
      • to respond to your requests related to your data subject rights 
      • to comply with our legal obligations (e.g. tax and accounting obligations)
      • to inform you about any changes to this Privacy Notice

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

5. On which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

      • Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you visit our Website for the first time, we ask for your consent for the data processing in the context of analytics. You have the right to withdraw your consent at any time, for example by changing Cookie Settings. Please note that this will not affect any processing carried out before you withdraw your consent. 
      • Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are a party, for example, in the context of communication channels or to support the operation to facilitate the delivery of requested services. 
      • Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, for complying with applicable regulations or resolution of legal disputes.
      • Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience. 

Please see for additional information the section with service specific information below. 

6. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the development team and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfill the purposes mentioned above, we  disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

      • External service providers: We share your Personal Data with external service providers who perform services on our behalf, like hosting, security, content delivery, web/social analytics and video hosting. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
      • Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
      • Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with  by clicking on the following link:

[Azerion Website Third Party Partners List]

 

7. Where will my Personal Data be processed?

In general, your personal data is stored on servers within the European Economic Area (“EEA”). To the extent that your personal data is processed by our partners in a country outside of the EEA, we have taken all such measures as are necessary to ensure an adequate level of protection for your personal data in accordance with the requirements of applicable data protection legislation, including but not limited to contractual safeguards.

 

8. How do we protect your Personal Data

Azerion has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect in relation to our Services. In order to help ensure a secure and safe experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.  

 

9. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfill the purposes for which the data was collected or to fulfill our legal obligations or necessary for the establishment, exercise of defense of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. Please see below for information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

 

10. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

      • Access the Personal Data we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.
      • Request an update or correction of your Personal Data so that it is always accurate.
      • Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
      • Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
      • Restrict the processing of your Personal Data, for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy. 
      • Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
      • Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

11. How can you contact us?

If you have any questions about this Privacy Notice or our use of your personal data, please contact our customer support website@azerion.com or our Data Protection Officer via e-mail at dpo@azerion.com.

12. Changes to our Privacy Notice

Azerion reserves the right to update or modify this Privacy Notice at any time. Accordingly, we regularly review this Privacy Notice and when there is a material change that will have a relevant impact on the processing of your personal data, these changes will be posted on this site.

This Privacy Notice was last updated on: 1 September 2022

Additional Information for California Residents

This section for California residents supplements the information provided in this Privacy Notice and applies solely to visitors, users, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.

We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)

Category G – Geolocation data

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. 

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

You have the right to opt out of any sale of your personal data by us to third parties. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

Service Specific Information

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting and content delivery 

The Website is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Analytics

We use analytics services to understand which features you like in our Services following changes to the website. For this purpose, we process information about your device and request data (including the URL of the current webpage and the website visited before). We also process your full IP address to allow us to better understand how you use our Services and to improve our websites. By activating IP anonymisation on Azerion, the IP address is shortened prior to transmission within the EEA or in other states party to the Agreement on the EEA.  We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access the Website for the first time.

Video player

We use Vimeo to display videos on our Website. This is a service of Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA, hereinafter referred to as “Vimeo”. If you visit one of our pages featuring a Vimeo plugin, a connection to the Vimeo servers is established. Here the Vimeo server is informed about which of our pages you have visited. In addition, Vimeo will receive your IP address, date and time of your visit to our Website. This also applies if you are not logged in to Vimeo when you visit our Website or do not have a Vimeo account. 

 

The information is transmitted to a Vimeo server in the US, where it is stored. If you are logged in to your Vimeo Account, Vimeo allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Vimeo account. 

 

We process this data on the basis of our legitimate interest, to provide video on our Website. For more information on how Vimeo handles Personal Data, please refer to the Vimeo Privacy Policy at https://vimeo.com/privacy

 

Communication Channels

We use a plugin called Gravity Forms to power any forms seen on our Website. This is a service of Rocketgenius, Inc., 1620 Centerville Turnpike, Suite 102, Virginia Beach VA 23464-6500, United States.

 

Data Captured through Gravity Forms will be used to contact you in order to respond to your enquiry. A backup of your data will also be stored in the database of our website, but will be deleted after 3 years. Only authorised individuals will be able to access your data, and it will not be disclosed to third parties.

We process this data on the basis of the performance of a contract as far as the information is required to answer your request. The continued storage of your request history is based on our legitimate interest, in order to improve our services or to resolve any potential dispute. If you  would like your data to be removed, please email dpo@azerion.com.

 

Recaptcha

We use reCAPTCHA by Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA) to secure forms and to prevent spam. reCAPTCHA is a free service that protects websites against spam and abuse. It uses advanced risk analysis techniques to keep people and bots apart. With the new API, a significant number of your valid human users will pass the reCAPTCHA challenge without having to solve a CAPTCHA. We process this data on the basis of our legitimate interest to protect our Website from bots and spam. By using reCAPTCHA, data will be transmitted to Google using Google to determine whether the visitor is human or spam. To see what data Google collects and what this data is used for, visit https://policies.google.com/privacy?hl=en-AT.

Further documentation can be found here: https://developers.google.com/recaptcha/, https://www.google.com/recaptcha/admin/create

 

Security Plugin

The “Wordfence Security” service, which is operated by Defiant Inc, 800 5th Ave., Suite 4100, Seattle, WA 98104, USA, is used to secure our online offering. The use is based on our legitimate interests.

 

The website uses the plug-in to protect against viruses and malware and to ward off attacks by computer criminals. In order to recognize whether the visitor is a human or a robot, the plug-in sets cookies. For the purpose of protection against brute force and DDoS attacks or comment spam, IP addresses are stored on the Wordfence servers. IP addresses classified as harmless are placed on a white list. Wordfence Security secures our website and protects visitors from viruses and malware. This represents a legitimate interest. The Live Traffic View option (real-time live traffic) of the plug-in is switched off, as it is not mandatory.

Further information on the collection and use of data by Wordfence Security can be found in the Defiant data protection information: https://www.wordfence.com/privacy-policy/.

 

WordPress Stats

We use WordPress Stats for a statistical analysis of frequency and form of visits on our Website. WordPress utilizes cookies which are stored on your device. These cookies allow for an analysis of how visitors use our Website. The information on the use of our Website generated by these cookies is stored on servers in the USA. Your IP address will be anonymized after recording and before storing. The cookies in question are persistent cookies. This WordPress Stats cookie remains on your device until you delete it. 

 

Storing of WordPress Stats cookies occurs based on our legitimate interest.

 

WordPress Stats is operated by the Irish subsidiary of Automattic at Aut O’Mattic A8C Ireland Ltd. Business Centre, No.1 Lower Mayor Street International Financial Services Centre, Dublin 1, Ireland.

 

Please refer to https://automattic.com/privacy for further information on the privacy policy of WordPress.