Last update: Desember 7, 2022
RELIZ LTD (Legal address: the Republic of Malta, 12 OFFICE 1 TREJQET HUGGIEGA, TRIQ VICTOR SCERRI, registration number: C 96147) («RELIZ», «Us», «We», or «Our») is a programmatic advertising platform («Platform») that allows advertisers and media buying agencies to bid automatically on display, video, mobile, and search ad inventory («Inventory») from a wide range of publishers and advertisers or supply partners («Clients»).
RELIZ works with developers, brands, and advertising agenciesas Clients to deliver advertising to individuals («End User», «End Users», «you», «your»). We do this through our Platform and service that we make available to our Clients.
RELIZ is committed to protecting the privacy of End Users when we process data about you via our proprietary Platform, when you visit our website at Reliz.com (the «Website») and when we engage in marketing activities based on contact information you provide to RELIZ or to third parties, through other means described in this Policy.
Processing of «Personal Data» (meaning any information which may potentially allow identification of individuals with reasonable means) is necessary for the performance of Our contractual obligations, for providing you with Our services, and for the operation of Our Platform, to protect Our legitimate interests and for compliance with legal and regulatory.
California End Users can opt-out of «selling» their personal information to RELIZ through a mechanism that allows you to adjust your preferences on the same page or app where you have found reference to RELIZ as a partner or by writing to firstname.lastname@example.org indicating your Google Advertising ID (android) or IDFA (ios). A «sale» of Personal Data under the California Consumer Privacy Act («CCPA») is defined broadly to include the «selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means» the Personal Data of an End User to another business or third party «for monetary or other valuable consideration.» Without this technical information, we cannot locate you and therefore comply with your request for exclusion. In the case of excluding the processing of your data for this purpose, you may still see advertisements, but these will, if necessary, be less adjusted to your interests. You may also appoint an authorized agent to exercise these rights.
PERSONAL DATA THAT WE COLLECT AND PROCESS
- Device and app information – this category includes your device’s type and model, system language, the device’s operating system (such as Android or iOS), Software Development Kit version (SDK), mobile carrier name, mobile browsers installed on the device (such as Chrome or Safari, your device’s IP address, and identifiers assigned to your devices, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or other types of unique device identifiers (a number uniquely allocated to your device by your device manufacturer).
- Ad information – this category includes information about the online ads and personalized content we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, whether you viewed, clicked on, or otherwise interacted with the ad, ad engagement history, and whether you visited the Client’s website, downloaded an app or purchased the product or service advertised.
- Location information – RELIZ collects information about your general location (such as country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is located precisely. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located.
- In addition, RELIZ may collect the precise location of your device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, Beacons signals, and cell tower ids that can be used to derive or estimate precise location, or other geo-location data), when location services have been enabled by the End User for the mobile app or website that uses our Software development kit (you typically have to choose to turn on device-based location services).
- Log information – this category includes the app or website visited, time zone, and network connection type (e.g., WiFi, cellular). Information from advertising partners and other third parties – this category includes information we receive from our Clients and other Partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Clients or third-party ad platforms choose to share with us. This information also enhances data points about a particular unique browser or device.
- Demographic Information – this category includes information like gender, age, marital status, and birth year.
Referred Collectively as «Ad Data»
SITUATIONS OF COLLECTION OF AD DATA
- RELIZ collects information when:
- managing the relationships between RELIZ and you;
- accessing and using our Platform;
- managing administrative;
- billing aspects fraud control;
- share updates and news related to RELIZ’s activities and services.
- RELIZ’s Services consist in allowing an advertiser to buy advertising with the help of automation («RELIZ Services»).
- For the purpose of performing RELIZ Services, RELIZ needs to collect minimum data from End Users. In the normal course of business, RELIZ shall not receive any directly identifiable Personal Data. «Personal Data» means any information that can help to identify a natural person or relate to an identified or identifiable natural person. In order to perform its Services, RELIZ will use its tracking and tagging technology on the Inventory. This technology allows RELIZ to collect End User basic information.
THE LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA
- We collect Personal Data from you where we have your consent to do so (e.g., through a check box). Your consent is securely stored and documented in our systems. You may withdraw any consent to personal data processing at any time by sending an email to: email@example.com specifying your request.
- You may also unsubscribe from our newsletter and external communications at any time by following the instructions contained in such communication.
- RELIZ makes an effort to obtain consent from the relevant data subject for every data processing. Given that RELIZ does not interact directly with End Users, consent must be obtained and transferred by other companies within the advertising supply chain that have a direct relationship with the End User.
- In addition to that, We may rely on the legitimate interest if we consider your privacy interests do not override this interest. This legal ground can intervene in our sales and marketing purposes. You can always choose to object to the processing of your Personal Data.
- In any case, RELIZ will process Personal Data only on the legal grounds allowed under EU Data Protection Laws, including GDPR (Contractual Necessity, Legitimate Interest, and Consent).
EU Persons Consent to Personal Data processing
- If you are an EU Person and to process your Personal Data, We need to receive your consent, as GDPR prescribes, We will process your Personal Data only in the case We have received your freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data («Consent»).
- Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, your Consent should be deemed given for all of them.
Non-EU Persons' Consent to Personal Data processing
- to process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to Us, as well as your Personal Data collected from your use of the Platform (i.e., your Personal Data which We collect automatically and/or from other Sources); and
RELIZ ROLE WHEN PROCESSING AD DATA
- Depending on the way RELIZ collects Ad Data, RELIZ will operate as an Independent Data Controller or just a pure Processor following the Clients’ instructions and directions, not having, in any case, a direct relationship with the End User whose information RELIZ will process. «Data Controller» means an entity that determines the purposes and means of the processing of Personal Data. «Processor» means an entity that processes Personal Data on behalf of a Data Controller.
PERMITTED USES OF AD DATA
- Serving ads and promoting apps — allowing Clients to promote advertising, apps, and content in their mobile apps or web display, and to allow Clients to bid on Inventory.
- Serve interest-based advertising and personalized content — enable our partners to infer interests and serve ads and personalized content to End Users based on their behavior, app activity, and inferred interests. We will not serve interest-based ads or personalized content based on information that we consider sensitive, such as race, religion, or health. An End User is not under any obligation to provide us with any Personal Data. In cases where an End User is from EEA, we serve them interest-based advertisements, only when they have given us their express consent to use their Personal Data to enable us to serve interest-based ads directed to them. Even if you opt out of interest-based advertising or have not given your express consent to interest-based advertising, you will still receive ‘generic’ ads from RELIZ which are context-based or better known as `contextual advertising`. The EEA links the EU member states and three EFTA states (Iceland, Liechtenstein, and Norway).
- Ad reporting and conversions — measure ad performance, report to Clients when and how End Users have viewed or clicked on their ads or visited their website, and report to Clients when and how ads were shown on their properties and were clicked on.
- Analytics and frequency capping — allow our Clients to analyze their applications (for this purpose, we use aggregated and anonymous benchmark data) and prevent End Users from seeing the same ad too many times. We also use usage information to analyze our web traffic, to figure out how often customers use parts of the site, to improve the site, and generally to make it appealing to as many End Users as possible.
- Fraud detection and prevention — identify invalid or incentivized clicks (or ad queries) and protect RELIZ and our partners from fraudulent behavior. Enforce our policies, resolve disputes, and communicate with you.
- Providing and improving our services — audit, research, and analyze information in order to maintain, protect, and improve our services and develop new services, and ensure that our technologies function properly.
Collectively, «Permitted Purposes»
- We share information about you with
- Our subsidiaries and affiliates;
- A Client whose app you have accessed – we share information about how you have interacted with that Client’s app and its ads and personalized content, if any tailored ad;
- A Client whose site or app you have visited – we share information about how you have interacted with that Client’s site, app, or its ads;
- With our service providers – we contract with companies who help with parts of our business operations (for example, storage of information, fraud control, and monitoring). We require that our service providers only use your information in connection with the services they perform for us;
- In connection with legal proceedings – when we are under a legal obligation to do so, for example, to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of RELIZ, our Partners or any other third party;
- In connection with a sale of our business – if a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale;
- In addition, we may disclose aggregated, anonymized information with other third parties but only in aggregate form or as may be required by law. This information cannot be used to identify you.
ONLINE BEHAVIORAL ADVERTISING
- We use third parties who collect data about their apps’ and sites’ visitors through their own cookies, web beacons, and other technologies regarding End User online activities in an effort to understand your interests and deliver you advertisements that are tailored to your interests. These third parties include Clients, and ad networks that may collect information about when End User views or interacts with one of their advertisements and may collect information regarding End User online activities over time and across different apps and websites. Like most Clients, we place advertisements where we think they will be most relevant to the recipient. When an End User visits a third-party website or app on which that network advertising company has purchased ad space, the advertising company can then recognize the individual’s interest and deliver one of our advertisements.
INFORMATION RETENTION AND ACCESS TO INFORMATION
- We may retain personally identifiable information we process on behalf of our Clients for up to twelve (12) months unless otherwise required by law or applicable contract. After the period, RELIZ may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes and enforce agreements. We may adopt shorter retention periods if so directed by our Clients.
- Please note that in most cases, we have no direct relationship with the End Users. An End User who seeks access or to correct, amend, or delete inaccurate information should direct his query to the relevant Client. If an End User requests us to remove any personally identifiable information relating to them, we will respond to their request within a reasonable timeframe.
- We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. We limit access to your information only to those employees or partners on a «need to know» basis to enable the carrying out of the agreement between us.
- While We seek to protect your information to ensure that it is kept confidential, We cannot guarantee its security. You need to help Us prevent unauthorized access to your account by protecting your device appropriately and limiting access to your account. You should also be aware that there is always some risk involved in transmitting information over the internet. While We strive to protect your Personal Data, We cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Platform, and you do so at your own risk.
- by transferring your personal information to a country that has been deemed to provide an adequate level of protection by the European Commission;
- by using specific contracts approved by the European Commission which give your personal information the same protection it has within the EEA including to the US;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
- RELIZ does not knowingly collect any personally identifiable information (including persistent device identifiers) relating to children under the age of 13. In addition, we require our Clients to certify to us that their services (such as their mobile apps) are not primarily directed to appeal to children under the age of 13 and to avoid sharing with us any personally identifiable information relating to children under the age of 13.
- Please note that while we strive hard to ensure that our policies are respected, we cannot be held responsible for the practices of our Clients. Our Clients are responsible to ensure that their privacy practices comply with applicable privacy laws and requirements.
- If you have knowledge of any incident in which we may be collecting personally identifiable information relating to children under the age of 13, that is directed to or aimed to appeal to an audience under the age of 13, please let us know immediately by contacting us at: firstname.lastname@example.org, and we will remove their personally identifiable information from our servers without delay.
- The following section will only apply if you are a Data Subject as defined under General Data Protection Regulation («GDPR») and also to the extent that RELIZ is in receipt of any Personal Data, as defined in Article 9 of the GDPR, originating in the European Economic Area (EEA).
THE RIGHTS OF DATA SUBJECTS UNDER GDPR
- Subject to possible restrictions under national law, you may have certain rights regarding the Personal Data that We collect on you:
- Right to access. youmay contact Us to get confirmation as to whether or not We are processing your personal data. When We process your personal data, We will inform you of what categories of personal data We process regarding you, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed, and the envisaged storage period or criteria to determine that period;
- Right to withdraw consent. In case Our processing is based on the consent granted, you may withdraw the consent at any time by contacting Us or by using the functionalities of the Application. You can withdraw your consent at any time by replying to the email with your withdrawal, and your Personal Data will be deleted immediately. Withdrawing consent may lead to fewer possibilities to use the Platform;
- Right to object. In case Our processing is based on a legitimate interest to run, maintain and develop Our business, you have the right to object at any time to Our processing. We shall then no longer process your personal data unless for the provision of Our services or if We demonstrate other compelling legitimate grounds for Our processing that override your interests, rights, and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, you have the right to prohibit Us from using personal data for direct marketing purposes, by contacting Us or by using the functionalities of the Application, or by unsubscribing possibilities in connection with Our direct marketing messages;
- Right to restriction of the processing. You have the right to obtain from Us restriction of processing of your personal data, as foreseen by applicable data protection law, e.g., to allow Our verification of the accuracy of personal data after you contest the accuracy or to prevent Us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when Our processing is unlawful. Restriction of processing may lead to fewer possibilities to use the Application;
- Right to data portability. You have the right to receive your personal data from Us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case Our processing is based on your consent and carried out by automated means;
- Right to complain. You have the right to complain to any relevant Data Protection Authority, in particular in the Member State of your residence, place of work, or the place of processing your personal data. If you wish to exercise any of the aforementioned rights, please get in touch with Us via email@example.com.
- You may have other rights under the law applicable in your jurisdiction. Consumers who reside in California have some additional rights with respect to their personal information under the CCPA. If you are a consumer residing in California, the next section supplements the main one and provides additional details about the personal information and the rights granted to you by the CCPA.
- Your Rights as a California Consumer. As a California consumer, you have the right to request access to personal information that we have collected about you in the last 12 (twelve) months. You may also request additional details about our privacy practices, including
- information about the sources of personal information,
- the commercial or business purpose for collecting or selling your personal information,
- the categories of third parties with whom we share your personal information and/or those with whom we have shared your information in the previous 12 (twelve) months,
- the categories of personal information that we have disclosed and sold about you in the previous 12 months.
- This request is limited to two times in a 12-month period.
- If you are a California consumer, you also have the right to request the deletion of your personal information in certain circumstances, to opt out of sales of personal information (as noted above) and to receive the same service and price, and to be free from discrimination, even if you exercise any of your rights under the CCPA.
- Please note that your request must include sufficient information to allow us to verify reasonably that you are the person about whom we have collected personal information.
- If you have any further questions and/or comments, please contact Us via email firstname.lastname@example.org.