Monkaze

PRIVACY POLICY

Version 1.5

We are company Monkaze Ltd, ID no.: 13648677, with it registered seat at 20-22 Wenlock Road, London, England, N1 7GU and we are monetizing internet advertising space of publishers registered on our platform to advertisers who chose this advertising space (“Services”). By providing Services, we allow advertisers to buy advertising space from publishers, so they can advertise their products and services more efficiently.

In this privacy policy we would like to inform you, our customers (publishers and advertisers), who use our website https://monkaze.com (“Website”) about how we handle your personal data as a data controller. As we are seated in United Kingdom, we process personal data according to Data Protection Act 2018. However, most of the processing is still governed by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”), as GDPR forms an integral part of the Data Protection Act 2018.

As a part of Services, you may have to create your user profile and provide us with other necessary information and by visiting our Website, some information about your device may be collected. In this document we describe how personal data are processed.

If you have any question related to our processing activities, please do not hesitate and contact us at 20-22 Wenlock Road, London, England, N1 7GU or at info@monkaze.com.

  1. WHAT PERSONAL DATA DO WE PROCESS?

In accordance with Services, we process:

  1. Personal data that are necessary for the usage of functions of the Website, specifically e-mail address, IP address and user agent. In connection with the provision of our Services, we need those personal data or the personal data of persons who represent company. The purpose of the processing is to ensure the provision of Services, the creation of a user account and to ensure mutual communication on the basis of Article 6(1)(b) GDPR. We may also need the personal data for the purposes of fulfilling our legal obligations under Article 6(1)(c) GDPR or for our legitimate interests of protecting and defending our own legal claims under Article 6(1)(f) GDPR. We are collecting those data during registration of user account or while you are using contact forms on Website.
  1. Personal data that are necessary for billing and verification, specifically name, surname, address, bank account details, telephone number, name, address and website of the company, position the company representative using Website. In connection with the provision of our Services, we need those personal data (of anyone who is representing company). The purpose of the processing is to ensure the provision of Services, to verify identity and category of the customer and to be able to bill you or company for the use of our Services on the basis of Article 6(1)(b) GDPR. We may also need the personal data for the purposes of fulfilling our legal obligations under Article 6(1)(c) GDPR or for our legitimate interests of protecting and defending our own legal claims under Article 6(1)(f) GDPR. We are collecting those data during registration of user account, while setting-up user account after registration or while you are using contact forms on Website.
  1. Cookies we obtain when you browse our website and are logged into user account. We only use essential cookies that are used for identifying the user and maintaining communication between individual user requests arriving at the server – for example, the user’s login status. Those cookies are session only, unless you are using permanent account login.

As mentioned above, personal data are used only for the mutual relationship, that means to provide you our Services or to communicate with you.

Personal data are also used for the purpose of fulfilling all legal duties that may arise in connection with provision of Services, for example to comply with accounting laws, tax laws etc.

Finally, personal data are also used to protect our claims under legitimate interest, so we can use them for the purpose of possible court proceeding and claims made by you, we also process personal data to protect our claims or to abide requests from relevant state authorities etc.

When you contact us through e-mail or contact form on our Website and you want to start cooperation with us, we will process your e-mail for the purpose of pre-contractual negotiations and for providing you with all necessary information under Art. 6.1.b) of GDPR. However, if we subsequently do not cooperate or your enquiry is not aimed at mutual cooperation, we will process the personal data on the basis of the legitimate interest of providing a response under Art. 6.1.f) of GDPR.

Also, your e-mail address may be used in two other ways. We may send you some technical notifications under our mutual relationship. These e-mails contain necessary information about our Website, changes, updates, Services etc. There is no way to reject these e-mails other than by ending mutual relationship. However, in some cases we may send you newsletters. We will only do this if you give us your active consent under Art. 6.1.a) of GDPR when registering your user profile during provision of Services.

Your personal data will not be used for any automated decision making, including profiling.

  1. DURATION OF PROCESSING OF PERSONAL DATA

Your personal data are always used only for a period necessary to achieve the purpose for which they were collected. For the purpose of provision of Services, we are processing personal data for the duration of your created user account and if you delete the account, we are archiving those data for next 5 years after the account deletion.

Additionally, the law may stipulate longer period for that we must keep some of the personal data, for example for the accounting purposes, so if law stipulates longer period, we must process personal data longer.

If you want to be acquainted with precise length of processing of your personal data, please write us on e-mail info@monkaze.com

  1. WHO HAS ACCESS TO YOUR PERSONAL DATA

We use other companies and their products to secure processing of personal data and providing you with the Services. Those other companies are so called data recipients.

We use these data recipients:

  1. Parker & Hill Inc., 160 Greentree Drive, Suite 101, City of Dover, County of kent, 19904, Delaware, USA, who provides us with accounting services. The company is located in the USA. As a part of our terms we have concluded, there is data processing addendum and standard contractual clauses as a safeguard for the transfer to the third countries.

We disclose your personal Data to other entities for legitimate business purposes including providing services to you, in accordance with applicable law. In addition, we may disclose your personal Data to:

  1. Your representatives as requested or authorized;
  2. Our vendors, subcontractors and service providers. We may share your data with our services providers who process your personal data to provide services to us or on our behalf. We have contracts with our service providers that prohibit them from sharing the information about you that they collect or that we provide to them with anyone else or using it for other purposes;
  3. Our parent company and our affiliates, which are entities under common ownership or control of our ultimate parent company. Our accountants, auditors, financial advisors, lawyers and other outside professional advisors to us, subject to binding contractual obligations of confidentiality;
  4. Governmental, legal, regulatory, or similar authorities, central and/or local government agencies, upon court order, request or where required, including reporting any actual or suspected breach of applicable law or regulation or our contractual agreements;
  5. Accreditation bodies;
  6. Third party Processors located anywhere in the world;
  7. Any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary to respond to a court order, or in the exercise or defense of legal rights in accordance with applicable law;
  8. Any relevant party for the purposes of prevention, investigation, detection or prosecution of a civil or criminal offence or the execution of civil or criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
  9. In the event that we sell or transfer all or any relevant portion of our business or assets including in the event of a reorganization, dissolution or liquidation, the information is transferred automatically to the new owner;

We may disclose the personal information we collect about our users when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.

We may share your information with advertisers and advertising networks that place ads (including sponsored links) on our Website. These companies may collect information, such as your computer's IP address, browser information, and search queries, as you use our Website and services. They also may use cookies and other technologies to collect this information when you visit our site as described below.

If we engage a third-party processor to process your personal data, the processor will be subject to binding contractual obligations to: (i) only process the personal data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the personal data; together with any additional requirements under applicable law.

  1. WHAT RIGHTS DO YOU HAVE?

You have the following rights in relation to our processing of your personal data:

  1. right of access to personal data;
  2. right to rectification;
  3. right to erasure (‘right to be forgotten’);
  4. right to restriction of data processing;
  5. right to data portability;
  6. right to object to processing;
  7. right to withdraw a consent; and
  8. right to file a complaint with respect to personal data processing.

Your rights are explained below so that you can get a better idea of their contents.

If you think that we are doing something that is not in accordance with law, you can file a complaint with the supervisory authority, i.e. the Information Commissioner’s office (https://ico.org.uk/).

The right of access means that you can ask us at any time to confirm whether or not personal data concerning you are being processed and, if they are, you have the right to access the data and information for what purposes, to what extent and to whom they are disclosed, for how long we will process them, whether you have the right to rectification, erasure, restriction of processing or to object; from which source we obtained the personal data, and whether automated decision-making, including any profiling, occurs on the basis of processing of your personal data.

The right to rectification means that you may request us at any time to rectify or supplement your personal data if they are inaccurate or incomplete.

The right to erasure means that we must erase your personal data if (i) they are no longer necessary for the purposes for which they were collected or otherwise processed; (ii) the processing is unlawful; (iii) you object to the processing and there exist no overriding legitimate grounds for processing; (iv) this is required of us based on a legal duty or (v) you withdrew consent on which the processing is based and there is no other legal ground for the processing.

The right to restriction of processing means that until any disputable issues concerning the processing of your personal data are resolved, we must restrict the processing of your personal data.

The right to data portability means that you have the right to obtain personal data that concern you and which you have provided to us and which are processed in an automated manner and on the basis of consent or contract, in a structured, commonly used and machine-readable format, and the right to have these personal data transferred directly to another controller.

The right to object means that you may object to the processing of your personal data that we process for the purposes of our legitimate interests, especially for the purposes of direct marketing. If you object to processing for the purposes of direct marketing, we will no longer process your personal data for those purposes.

The right to withdraw a consent means that you may any time withdraw your consent you give us. You may withdraw your consent when we are sending you newsletters with which you agreed. You may withdraw it by clicking “unsubscribe” in every newsletter we send you or by contacting us at e-mail stipulated above. Do not forget that before you withdraw your consent our processing is legitimate, and it is not affected by the withdrawing.

You can exercise all your rights by contacting us at the following e-mail address: info@monkaze.com.

  1. INTERNATIONAL TRANSFER OF PERSONAL DATA

Because of the international nature of our business, we may need to transfer your personal data to third parties as noted above in connection with the purposes for which you provided it to us and as set forth in this privacy policy. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements, including data protection laws which are of a lower standard to those that apply in the country in which you are located or are a citizen.

We transfer your Personal Data to other countries on the following basis:

  1. Adequacy decisions;
  2. Binding Corporate Rules; or
  3. Standard Contractual Clauses; or
  4. Other valid transfer mechanisms.

If you want more information about the safeguards applied to international transfers of personal data, please contact us.

  1. HOW DATA IS PROTECTED

We have implemented appropriate technical and organizational security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access in accordance with applicable law. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls.

While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the personal data we maintain about you is accurate and current. We are not responsible for protecting any personal data that we share with a third-party based on an account connection that you have authorized. You are responsible for ensuring that any personal data that you send to us are sent securely.

  1. CALIFORNIA RESIDENTS RIGHTS

California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. In addition, California residents have the right to know if we respond to do not track signals or cookies. We do not respond to such signals or cookies. As stated in this privacy policy, you have agreed to allow us to share information with third parties for their direct marketing purposes until you remove your information; and thus, you have agreed to this disclosure. California customers may request further information about our compliance with this law by sending us an email at privacy@monkaze.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.

  1. COOKIES AND TECHNOLOGY TRACKING

We use cookies, pixel tags, web beacons, and similar files or technologies to collect and store the information we automatically collect about your computer, device, and product usage. We use the term "cookies" in this policy to refer to cookies and all such similar technologies that collect information automatically when you are using our Website where this privacy policy is posted. We may process your personal data through cookie technology. We use cookies on our website to enhance the experience while using the Website. Where applicable, this Website uses a cookie control system allowing you on your first visit to the website to allow or disallow the use of cookies on your computer / device. The Website complies with recent European Union Member legislation requirements for Websites under such directive to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's computer / device. If you wish to deny the use and saving of cookies from this Website on to your computer's hard drive, you should take necessary steps within your web browsers security settings to block all cookies from this website and its external serving vendors. If you continue to use this Website without taking action to prevent the storage of this information, you are effectively agreeing to this use.

Cookies are small files saved to the computer's hard drive that track, save and store information about the user's interactions and usage of the website. The use of cookies helps us analyze data about web page traffic and improve our website in order to customize it to the users' needs. We use this information for statistical analysis purposes and then the data is removed from the system.

  1. LOG FILES

We automatically collect and store certain information in server logs the following:

  1. Search activity when you use web search services (such as search queries) ("Search Data");
  2. Internet protocol address ("IP Address");
  3. The type of browser you are using when using our Services, including your browser's "user agent" (e.g., Internet Explorer, Safari, and other browsers);
  4. Device event information such as crashes, system activity, hardware settings, browser language, and the date and time of your request and referral URL;
  5. Your geographic location;
  6. The Domain name of your Internet Service Provider;
  7. The source of traffic acquisition;
  8. Date of traffic acquisition;
  9. Views on landing page, clicks on an action button on landing page, order pages and abandonment.
  1. CONTACTING US

You can contact us by e-mail at privacy@monkaze.com or on our address 20-22 Wenlock Road, London, England, N1 7GU.

This policy is effective from 22.11.2022.