Eskimi Privacy Policy

1. Why should I read this Privacy Policy?

This Privacy Policy (‘Policy’) describes how Eskimi (hereafter referred to ‘we’, ‘us’, ‘our’) collects, uses, discloses, and stores your personal information and what statutory rights you have under applicable data protection laws. We may amend this policy unilaterally from time to time. Any such amendments will be effective immediately upon publication. Please visit our website at www.eskimi.com regularly for the latest version of this policy.

2. Why do you collect, and how do you use my information?

2.1. To provide you with our services 

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When you are a  representative of a company which is our client
Name, surname, position, email address, telephone number, company’s name, company’s website, country, type of ordered services, payment amount, expected monthly ad spend, the way you found out about us, username, password
Contract
No
For the duration of the contract with us and 10 years after its termination

2.2. To enable our clients to show you online advertisements that are relevant to you

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When our clients show you online advertisements that are relevant to you
Mobile advertising ID or Cookie ID (hereinafter collectively referred to as User ID), imprecise location, browser information, operating system, internet service provider, information about your visit on our client’s site, IP address, type of device, data regarding your activities on the website, app or other digitial content source, other data provided by our client, information on gender, year of birth, information on countries / cities that your User ID was seen in,  total number of page views, how you are connected to the internet, internet site ID where you were browsing, last time you visited a specific site, first and last time your User ID was seen, number of pages you view per day, your interests categories, information on your consent to receive relevant ads
Legitimate interest to enable our clients to show you relevant online advertisements
No
No longer than 10 years, unless you opt-out earlier

2.3. To provide you with customer support

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When you contact our customer support 
E-mail address, subject of your inquiry, date of your inquiry, content of your inquiry, attachments to your inquiry, your name and (or) surname provided in your inquiry, reply to your inquiry, information provided by you
Consent
No
No longer than 5 years  following the end of such communication

2.4. To operate our website, ensure its security

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When you are browsing our website
Device information and ID, IP address, geographical location, browser type and version, operating system, device type, screen resolution and your location data as well as information on the use of our website
We have a legitimate interest to properly administrate our website and ensure its security
No
5 year after your last visit of our website

2.5. To manage our social media profiles

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When you interact with our social media profiles
Name and surname of your social media profile, message, time, and date the message was received, content of the message, message attachments, response to the message, time of response to the message, information about our rating, comments on a post, post shares, information about post reactions
Consent 
No
10 years after you interact with our social media profiles

2.6. To provide you with information about our products and services

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When we provide you with information (e.g., via phone or email) about our services and/or products
Your name, surname, e-mail address, your answers to the questions in the customers satisfaction survey, date of the completion of the customer satisfaction survey, information on your LinkedIn profile, workplace, position, country, region, telephone number, whether you opted-out from receiving information from us, record of the call, 
Consent

We have a legitimate interest to ask your opinion about our services/goods 

Customer relationship between you and us
No
No longer than 5 years, unless you opt-out earlier 

2.7. To carry out the selection of potential employees

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When you apply for a job or we review you as a potential candidate
Name and surname, e-mail, phone number, CV, work experience, and other information you provide us with
Consent

Contract (taking steps to enter into an employment contract with us)

We also have a legitimate interest to contact you when you publicly disclose your information on professional social media platforms
It is a requirement necessary to enter into a contract only where we intend to enter into an employment contract with you. If you do not provide this information, we will not be able to enter into an employment contract with you.
3 years after the end of the relevant recruitment process

5 years after you give us your consent or after we collect the information from professional social media platforms

2.8. To fulfil statutory accounting requirements

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
When you use our services
Name, surname, e-mail address, telephone number, address, invoices, reports, accounting documents, payments, paid amounts, and other information we are statutorily required to collect
We have a legal obligation
It is a statutory requirement. If you do not provide this information, you will not be able to buy goods or services from us
10 years following a transaction

2.9. To establish, exercise or defend legal claims

When is this relevant for me?
What information do you collect about me?
What is your legal basis for collecting my information?
Am I obliged to provide this information?
How long do you store information about me?
In case we become a party to a legal process to which you are subject, or we are statutorily required to collect or provide information about you
All of the aforementioned information, accounting and legal case files, legal documents, other information you provide us with, additional information that we are statutorily required to collect and/or provide
We have a legal obligation to process this information, in other cases we have a legitimate interest to defend our rights and interests
Provision of information may be a statutory requirement.
10 years following the end of the contractual relationship with us or, whichever is longer, for the duration of the legal process and 3 years after a final authority decision came into full force

3.0. Where do you collect my information from?

Information source
Purpose of collecting information 
  • Our clients 
  • Publishers (digital content providers)
  • Supply-Side-Platforms (platforms that help publishers to manage their advertising inventory)
  • Ad exchanges (digital marketplace where publishers and advertisers come together and buy/sell advertising space)
To provide our services and enable our clients to show you relevant ads 
Eskimi’s group companies
To operate our business
Social media service providers
To manage our social media profiles 
HR service providers
To carry out the selection of potential employees 
Law enforcement authorities, courts, parties that are subject or related to legal processes
To establish, exercise or defence legal claims 

4. Who do you share my data with?

We share your information with information recipients in cases where necessary for the above-described purposes and allowed in accordance with applicable laws.
No
Recipients or categories of recipients
Location of the recipient
What is the legal basis to transfer my information outside the EEA?
4.1.
Publicis Group (our client)
France
N/A
4.2.
Havas Group (our client)
France
N/A
4.3.
WPP plc (our client)
United Kingdom
4.4.
MailerLite (marketing service provider)
Lithuania
N/A
4.5.
Sage HR (HR service provider)
United Kingdom
4.6.
Jira (team and work management tools providers)
Australia
4.7.
PipeDrive (CRM tools provider)
US
4.8.
LinkedIn (social media service provider)
US
4.9.
Google (cloud computing, work management, communications service provider)
EU/US
4.10.
Facebook (social media service provider)
EU/US
4.11.
Other companies of our group
Worldwide
4.12.
Other service providers (such as providers of servers and maintenance, communication tools service providers, service providers used for data analysis, marketing service providers, compliance and legal service providers) and clients
Worldwide
In cases where we transfer information outside the EEA, we rely on the European Commission’s Adequacy Decisions about certain countries or use Standard Contractual Clauses approved by the European Commission.
4.13.
State institutions and regulatory authorities
Worldwide
In cases where we transfer information outside the EEA, we rely on the condition that the transfer is necessary for the establishment, exercise or defence of legal claims.

5. What statutory rights do I have regarding my information?

Subject to conditions and limitations established by applicable laws, you have the rights:
  • to know about the personal information collected, disclosed, or sold and to request access to that information; 
  • to correct inaccurate or incorrect information or to supplement it when it is incomplete; 
  • to delete the information we have about you;
  • to restrict the use of your information where you challenge the accuracy of the information, object to the processing of the information or need your information for legal purposes; 
  • to request your information in a structured, commonly used and machine-readable format
  • to object to the processing of the information. It is relevant where the collection and use are based on a task carried out in the public interest or in the exercise of official authority vested or legitimate interest, including profiling, as explained in Section 2 of this policy, or where you object to the collection of your personal information for direct marketing purposes.
  • to withdraw any consent given to us regarding the processing of your information. You have the right to withdraw any consent given regarding the processing of your information where the processing is based on consent, as explained in Section 2 of this policy, and you seek to withdraw it at any time;
  • to file a complaint with supervisory authorities;
  • not to receive discriminatory treatment while exercising your rights. 
If you want to be excluded from targeted advertising, you can always do so by opting out from further data processing for purposes of delivering ads to you. Click to Opt-Out of targeted advertising
More detailed information on your rights and the cases where they are applicable are provided in the sections below.

6. What is my right to know about the personal information collected, disclosed, or sold?

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and verify your request, we will disclose to you the categories of information we collected about you, the categories of sources for the information we collected about you, our business or commercial purposes for collecting that personal information, the categories of third parties with whom we share that information, the specific pieces of information we collected about you and other information that we are obliged to provide under the applicable laws. We have disclosed the information to third parties for business or commercial purposes as described in Section 5 of this policy. 
Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested. We may ask you to fill in a special Data Subject Access Request Form in order to facilitate the process of providing access to your data. For more information please refer to our Data Subject Access Request Procedure.

7. What is my right to request deletion of the information?

You have the right to request the deletion of your information collected and maintained by us in the cases where (i) information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw consent on which the processing is based, and there is no other legal ground for the processing; (iii) when you object to the processing, and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes; (iv) the information have been unlawfully processed; (v) where the information has to be erased for compliance with a legal obligation; (vi) the information have been collected in relation to the offer of information society services directly to a child and subject to consent. Once we receive and verify your request, we will delete (and direct our service providers to delete) your information from our records unless applicable laws do not provide for the deletion of the information in a particular case (for instance, retaining the information is necessary for us or our service provider(s) to complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, comply with a legal obligation, make other internal and lawful uses of that information that are compatible with the context in which you provided it).

8. What is my right not to receive discriminatory treatment while exercising my rights?

When you exercise your rights enshrined in applicable laws, you also have the right to non-discrimination. For example, because you exercised your rights under applicable laws, you will not be denied any goods or services, charged with a different price, provided a different quality of goods and services etc. 

9. Do you engage in automated individual decision-making, including profiling?

No, we do not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you.

10. Does your website use cookies or similar tracking technologies?

Yes. Cookies are small textual files containing an identifier that is sent by a web server to your web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

11. How can I manage cookies?

When you visit our website, we ask for your consent for the use of non-essential cookies. However, essential cookies are enabled by default because they are a prerequisite for our website to function. We respect your preferences concerning cookies, and you can easily manage and disable them below.

Our website places the following cookies on your device:
Please state your consent ID and date when you contact us regarding your consent. 
You can also configure your browser to decline some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies, you may be unable to access certain areas or features of our website. You can control the use of cookies by adjusting your browser settings. To find out how to manage cookies in your browser, please visit one of the links below:

12. Do you process information about minors?

We do not knowingly process the information of minors under 18 years of age. By using the website and/or our services, the user asserts they are not under 18 years of age. If you are under 18 years of age, please do not use our website and/or services and do not submit any information through our websites or services without the parents’ permission. If we become aware that we have inadvertently received information of minors under 18 years of age, we will delete such information from our records.

13. How do I submit a request / contact your DPOs?

If you would like to exercise your rights described above or have any other concerns relating to your information processing, please submit a request to us via e-mail at privacy@eskimi.com.

14. Can I use an authorized agent?

Sure. You may use an authorized agent to submit a request to opt out on your behalf if you provide us with the authorized agent written permission to do so. If this is the case, please provide us with a copy of the said permission as instructed under Section 10 of this policy. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. 

15. TCF Details

Eskimi participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Eskimi’s identification number within the framework is 814.
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