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 you act as a representative of a company that uses our programmatic advertising platform or orders advertising services from us, we process your Data in order to provide and manage these services.This includes creating and administering your user account, enabling access to the platform, communicating with you regarding campaign setup and performance, and ensuring the proper delivery and performance of the programmatic advertising services ordered by your company.
Legal basis for the processing
Categories of the Data concerned
Is the provision of the Data a requirement?
Contract
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
Yes - this is a contractual  requirement. If you do not provide this data, you will not be able to use our services.

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

When you visit websites, mobile applications, or other digital properties where our clients use our advertising technology, we process certain Data to enable the delivery of online advertisements that are relevant to you.
Legal basis for the processing
Categories of the Data concerned
Is the provision of the Data a requirement?
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 digital 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
No

2.3. To provide you with customer support

When you submit an inquiry, request, or complaint, we process the Data listed below in order to provide you with appropriate support and to ensure proper handling of your case.
Legal basis for the processing
Categories of the Data concerned
Is the provision of the Data a requirement?
Consent
Legitimate interest to handle your inquires
Name, surname, e-mail address, telephone number, residential or business address, the content of the inquiry, request, or complaint, information and documents related to the submitted inquiry, request, or complaint, responses, correspondence records, call recordings, chat transcripts, and any other information voluntarily provided by you in the course of communication.
No

2.4. To operate our website, ensure its security

To ensure the security, stability, and proper functioning of our website as well as to protect against fraud, abuse, and unauthorized access, we automatically collect and process certain technical and usage-related data. This information also helps us monitor performance, detect errors, implement services upgrades, develop new features, and improve the overall user experience.
Legal basis for the processing
Categories of the Data concerned
Is the provision of the Data a requirement?
Legitimate interest to properly administrate our website and ensure its security
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
No

2.5. To manage our social media profiles

When you register on our website, provide us with your consent, or when we have a legitimate interest, we may process your Data for marketing purposes, including sending you relevant offers, updates about our or our partners’ services and goods, and requests for feedback about the services we provide. In addition, when you interact with our social media accounts, we process the Data generated from these interactions in order to administer and improve our social media presence and to communicate with you effectively.
Legal basis for the processing
Categories of the Data concerned
Is the provision of the Data a requirement?
Consent
Legitimate interest (to inform you about our services and goods)Customer relationship
Name and surname, e-mail address, social media profile information, messages and their content, message attachments, date and time of received and sent messages, our responses and timestamps, comments on posts, post reactions, post shares, information about our ratings, and your answers to customer satisfaction surveys (including the date of completion).
No

2.6. To carry out the selection of potential employees

When you apply for a vacant position in our company or when we contact you regarding job opportunities, we process your Data related to the recruitment process.
Legal basis for the processing
Categories of the Data concerned
Is the provision of the Data a requirement?
Consent Legitimate interest to contact you regarding job opportunities in our company
Name, surname, place of residence or residential address, e-mail address, telephone number, information about work experience (employer, period of employment, position, responsibilities, achievements), information about education (educational institution, period of study, degree and/or qualification obtained), information about training (courses attended, certificates obtained), information about language skills, IT skills and other competences, other information provided in the CV, cover letter or other application documents, name of the referee/recommending person, content of the recommendation, summary of the interview, notes and opinions of the recruiter, results of candidate testing.
No

2.7. To comply with legal requirements and defend our legal interests

We will retain the Data in accordance with statutory limitation periods to defend our rights and legal interests if necessary. Some data must be retained to comply with legal requirements in accounting, archiving, and other areas. In rare cases, if you become involved in a legal process to which we are a party, we will use this data for that legal process.
Legal basis for the processing
Categories of the Data concerned
Is the provision of the Data a requirement?
Legal obligation
Legitimate interest in protecting our rights and legal interests
Name, surname, email address, contracts, legally binding documents and data, correspondence, legal documents, pleadings, annexes, court documents, investigative information, information about convictions and criminal offences, and any other Data provided and collected
When the processing of your Data is required under applicable laws, providing this data becomes a legal necessity. If you are unable to provide this data, unfortunately, we will not be in a position to offer our services to you.

3. How long do you keep my data?

We retain the Data in a form that allows your identity to be determined no longer than necessary for the purposes for which the Data is processed, and in accordance with legal requirements. We will retain information necessary for the protection of our legal interests for 10 years after the termination of relationship with you.

4. Where do you collect my information from?

We collect most of the information from you. In addition, for certain purposes, we may receive information from other sources, as explained below.
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 

5. Who do you share my information with?

We share your information with information recipients in cases where necessary for the above-described purposes and allowed in accordance with applicable laws.
Recipients or categories of recipients
What is the legal basis to transfer my information outside the EEA?
Third country
Safeguard measure or exemption allowing the transfer
Lawyers, notaries, bailiffs, data protection officers, auditors, tax, business, HR and other consultants
---
Providers of IT tools and services, electronic communications service providers, travel agencies, insurance companies, archiving and other service providers
---
State labour, social security, tax, supervisory authorities, police, prosecutors, courts, law enforcement and other state and local authorities
---
Google Inc. (IT infrastructure and services provider)
USA
Facebook (Meta) (social media service provider)
USA
LinkedIn (social media service provider)
USA
Potential or actual purchasers of thebusiness or part of it and their authorised advisers or representatives
Various

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

Subject to conditions and limitations established by applicable laws, you have the rights:
My Right
Summary
Right of access
The right to obtain confirmation from us as to whether Data relating to you is being processed and, if such Data is being processed, the right to have access to the Data and information about the processing.
Right to rectification
The right to require us to rectify inaccurate Data relating to you.
Right to erasure (‘right to be forgotten’)
- when Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- when you withdraw consent on which the processing of Data is based and there is no other legal ground for the processing;
- when you object to the processing of Data and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes;
- where the Data have been unlawfully processed;
- where the Data have to be erased for compliance with a legal obligation;
- where the Data have been collected in relation to the offer of information society services directly to a child and subject to a consent.
Right to restriction of processing
- where the accuracy of the Data is contested by you;
- where the processing of Data is unlawful and you oppose the erasure of the Data and request the restriction of their use instead;
- where we no longer need the Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
-where you have objected to the processing of the Data and until it has been verified whether our legitimate interests override yours.
Right to data  portability
where you seek to receive the Data you have provided in a structured, commonly used and machine-readable form or to transmit those data to another controller, the processing is based on consent or on a contract and is carried out by automated means.
Right to  object
where the collection and use of the Data is 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 3 of this Privacy Policy, or where you object to the collection of your data for direct marketing purposes.
Right to withdraw consent
where the processing of Data is based on consent, as explained in Section 3 of this Privacy Policy, and you seek to withdraw it at any time.
Right to lodge a complaint
Right to lodge a complaint with a supervisory authority

7. What is my right to opt-out of targeted advertising?

If you wish to opt out of targeted advertising, you can do so at any time. When you opt out, we will stop using your information for personalised advertising and will take all necessary steps to ensure that no targeting based on your User ID is applied.

Opting out on websites

You can opt out by clicking the following link: Click to Opt-Out of targeted advertising. When you opt out, an anonymous “opt-out cookie” will be placed in your browser to record your choice. Your opt-out will remain active as long as this cookie is not deleted.
Please note that:
• the opt-out applies only to the specific browser and device you are using;
• if you clear cookies, use private browsing, or switch browsers or devices, you will need to opt out again;
• Some browsers (such as Safari) may restrict cookies, which may affect the functionality of the opt-out.

Opting out in mobile applications

For mobile apps (iOS, Android, and other devices), you can opt out of personalised advertising through your device settings:
• iOS devices: Settings → Privacy → Tracking → disable “Allow Apps to Request to Track”.
• Android devices: Settings → Google → Ads → enable “Opt out of interest-based ads” and/or “Reset advertising ID”.
Please note that the exact steps may vary depending on your device model and operating system version.

Effect of opting out

If you choose to opt out:
• we will not use your User ID for targeting;
• we will not create or update any profiles related to your device;
• you may still see ads, but they will not be personalised.

8. 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.

9. 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.

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:
Cookie category
Cookie name
Cookie purpose
Cookie  expiry
Functional
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#.#-#-#-#-#.queue
#.#-#-#-#-#.reclaimEnd
#.#-#-#-#-#.reclaimStart
__cf_bm
__eConsent
CONSENT[x2]
bscookie
CookieConsent[x2]
debug
li_gc
test_cookie
Used to contain user’s survey and  quiz answers in Local Storage.
Used to contain user’s survey and  quiz answers in Local Storage.
Persistent
Persistent
4.2.
Sage HR (HR service provider)
United Kingdom
4.3.
Jira (team and work management tools providers)
Australia
4.4.
PipeDrive (CRM tools provider)
US
4.5.
LinkedIn (social media service provider)
US
4.6.
Google (cloud computing, work management, communications service provider)
EU/US
4.7.
Facebook (social media service provider)
EU/US
4.8.
Other companies of our group
Worldwide
4.9.
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.
4.10.
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.

10. 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.

11. 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 dpo@eskimi.com.

12. 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. 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.

13. Do you participate in the TCF?

We participate in the IAB Europe Transparency & Consent (TCF) and comply with its Policies and Specifications. Our IAB Europe Vendor ID is 814. More information about the framework is available at: https://iabeurope.eu/tcf/