Entering into force on 17 October 2023.
The purpose of the present Privacy Policy is to provide data subjects (including You) with information about the data processing performed by Monetization Solutions Inc (registration code 7254995), address Corporation Trust Center, 1209 Orange Street, Wilmington, New Castle, Zip Code 19801, Delaware, USA and its subsidiaries, namely by SIA Monetization Solutions (registry code 40203021882) address at Rīga, Lāčplēša iela 24 - 49, LV-1011 related to its products and services.
This Privacy Policy will explain and give You information regarding:
a. the purposes of the processing and how your personal data is processed
b. on what legal grounds your personal data is processed
c. which personal data is collected and further processed
d. how long it is kept
e. how it is protected and safeguarded
f. who has access to your personal data
g. what are your rights and how you can exercise them
h. who to contact if you have questions or complaints.
Monetization Solutions Inc owns the intellectual property rights of the IT solutions of the Monetization Solutions group and the trademark Monetizr. Monetization Solutions Inc offers advertisement solutions to gaming companies and to non-gaming companies that wish to market their products and/or services to consumers to enable consumers outside of the European Union (hereinafter the EU) to experience a more fulfilling gaming experience and to get new type of rewards and benefits. SIA Monetization Solutions uses the technology developed by Monetization Solutions Inc and offers advertisement solutions to gaming companies and to non-gaming companies that wish to market their products and/or services to consumers in the EU to enable consumers in the EU to experience a more fulfilling gaming experience and to get new type of rewards and benefits.
1. Scope of processing
We collect your personal data when you use our website https://themonetizr.com or through email communication when you respond to questionnaires or other inquiries by your choice.
We also process your personal data in the process of providing digital advertising services on behalf of our publisher clients whose services you use.
The exact types of personal data and the purposes for processing are described below.
2. Which personal data is collected and further processed
We collect personal data in two ways: data you directly provide to us and data generated by your activity on the websites and mobile applications of third parties, namely using your preferred gaming site(s).
2.1. Data you directly provide. You can choose to voluntarily provide us personal data when you use our website or when you click on an advertisement and make the choice to opt-into an advertisement campaign. This data enables us to serve the advertising campaigns and rewards to you. You can also provide your personal data to us based on your consent when you answer questionnaires regarding your preferences. In the above-mentioned cases the personal data we process is the following:
2.1.1. User provided data when you answer to questionnaires regarding your preferences and when you give feedback regarding campaigns you entered,
2.1.2. Your e-mail address,
2.1.3. Your IP address,
2.1.4. Your device characteristics,
2.1.5. Your device identifiers.
2.2. Data generated by your activity. In order to ensure the effective functioning and security of our services and to better understand which campaigns to serve you, as you browse our website or a third-party website or app (namely your gaming service provider´s website) we automatically collect:
2.2.1. Your internet protocol (IP) address.
2.2.2. Device characteristics and software information such as your browser specifications and operating system.
2.2.3. Device identifiers, such as Android Advertising ID (AAID), Identifier for Advertisers (IDFA), ANDROID_ID and identifier ForVendor (iOS).
2.2.4. Non-precise location data, such as location acquired from internet provider ip address lookup.
2.2.5. Advertisement click data.
This information is collected using various technologies, including cookies which are small text files stored in your browser. If you have registered to a campaign and are logged-in, your browsing activity is linked to your device identifiers so that we can personalize your experience through your gaming service provider´s website, including for future visits.
We do not collect nor process sensitive data.
We do not knowingly collect personal information from, or serve advertisements to, children as defined and required by applicable laws. If you believe we have collected any personal information from or about a child, or if you believe a mobile application may be exclusively designed for, directed to, or pass personal information knowingly from, children, please contact us via email at privacy@themonetizr.com.
3. The purpose and legal ground for personal data processing
We collect and process your personal data based on your consent and/or based on your consent as collected by Monetizr’s publishing or Monetizr´s other partners.
We may process your personal data based on legitimate interests to prevent and detect fraud in gaming campaigns and in collecting rewards and to ensure security, and fix errors.
Data you provide directly is typically kept until either (1) you unsubscribe from the service requested or until (2) two years after your last transaction. We store data about your activity on our websites for two years, after which time it is deleted. We keep data on email activity for two years, after which time it is deleted.
4. How long is your data kept
Data you provide to us directly is typically kept until either (1) you unsubscribe from the service requested or until (2) five years after your last transaction whichever is sooner. We store data about your activity for five years, after which time it is deleted.
5. How is your data protected and safeguarded
We use industry standard technical and organizational measures to process, store and secure your personal data. We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks and make sure our employees are aware and use all the security features designed to protect and safeguard your personal data.
We have specific data processing agreements in place with our contractors and partners we offer our services to, under which we and our contractors and partners agree to fulfill and enforce all the relevant personal data protection statutory requirements and standards in place.
6. Who has access to your personal data
6.1. In general, access to your personal data is limited to appropriate staff within either Monetization Solutions Inc or SIA Monetization Solutions. In some circumstances we make your data available outside the service provider you have chosen, such as for:
a. Reward processing: we have third party partners who provide the specific rewards advertised through campaigns to you.
b. Analytics: we use third-party services, to help us understand your behavior by allowing the service access to the data generated by your activity and store it using cookies. This data is processed in a way that does not directly identify you.
c. Email communications.
d. Online surveys: we use third-party services to run online surveys for you.
e. Programmatic Advertising Partners: we use third-party partners, who may help facilitate the filling the programmatic demand of ad opportunities and ad optimization for certain ad campaigns
f. Advertising Measurement Partners: we use third-party partners, who may help facilitate the measurement of performance of advertising campaigns.
g. Cloud Service Providers: we use cloud service providers, who host our data, server infrastructure, and services.
6.2. We may also disclose information based on applicable law if we have a good faith belief that disclosure of such information is reasonably necessary to:
6.2.1. comply with any applicable law, regulation, legal process or governmental request;
6.2.2. enforce our agreements and policies, including investigations of potential violations thereof;
6.2.3. investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
6.2.4. to establish or exercise our rights to defend against legal claims;
6.2.5. prevent harm to the rights, property or safety of us, our users, yourself or any third party;
6.2.6. for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights; or
6.2.7. when we are undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of our assets.
7. Your rights as data subject
Providing your information is voluntary, however, in the absence of your data, we do not have the opportunity to serve you with advertisement and campaign information and you may not be able to participate in open campaigns.
You have the right to:
a. obtain access to the personal data held by us about you
b. to request the rectification or erasure of your personal data
c. to request the restriction of processing
d. object to processing
e. data portability
f. withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
How you can control the processing of your data from your device
Please note that you can always decide how different apps use your data. You can always opt out of the disclosure of Advertising ID and change the volume and the way your data is used. Updated versions of iOS, and Android, enable you to control how apps can collect the Advertising ID. For managing your data please follow the below instructions:
For iOS mobile devices, go to “Settings” from the device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” Please note that if you use more than one device, you need to opt-out separately in each device.
For Android mobile devices, go to “Google Settings” on the device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” and/or please follow the instructions set forth at:
https://support.google.com/ads/answer/1660762 (under Mobile Controls). Please note that if you use more than one device, you need to opt-out separately for each device.
You can review http://www.networkadvertising.org/mobile-choices for more information regarding how you may opt out via the mobile platform. If you would like to disable the collection of your mobile device geolocation information, you can make this selection on your mobile device. To learn more about interest-based advertising, and to access the opt-outs of certain online advertising companies, visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/#completed or Digital Advertising Alliance (DAA) at http://www.aboutads.info/choices/. You should complete the opt-out process for all devices and browsers you use. If you opt-out of targeted advertising, you will still receive general advertisements.
For any request concerning the processing of your personal data, we invite you to contact us at privacy@themonetizr.com
8. Data transfer
Your personal data shall not be transferred to third parties, except for the cases listed and explained in this privacy policy.
SIA Monetization Solutions may need to transfer your personal data to Monetization Solutions Inc to use the technology created and owned by the latter for providing you with our services. Monetization Solutions Inc may in return need to transfer your personal data to SIA Monetization Solutions for the same purposes. Both group companies have contractors and business partners outside the EU and the transfer of your personal data outside of the EU is thus necessary to carry out and perform our services to you.
Monetization Solutions Inc and SIA Monetization Solutions have in place the standard contractual clauses for cross-border data transfers and for personal data transfers outside of the EU. Such standard contractual clauses are in place between the group companies and between the third-party service providers and partners to facilitate your access to our services. Monetization Solutions Inc and SIA Monetization Solutions undertake to make sure that we only transfer your personal data to locations that ensure a similar degree of protection to the processing of personal data as under the GDPR. To meet this requirement, we will:
a. only transfer your personal data to countries that have been deemed to provide an adequate level of protection for the processing of personal data by the European Commission.
b. Use specific standard contractual clauses designed by the European Commission which give personal data the same protection it has in the EU for certain service providers outside of the EU
c. Transfer data to third parties located in the US if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the US.
9. Contact
Our DPO is at your disposal at privacy@themonetizr.com
10. Judicial remedy
You can always contact the Latvian data protection inspectorate at pasts@dvi.gov.lv
11. Changes to this Privacy Policy
We may revise this privacy policy from time to time. The latest published version of this privacy policy will govern our processing of your personal data and is available at https://themonetizr.com/privacy-policy. The referred location on our website shows you the last, applicable and up to date version of our privacy policy.