PRIVACY STATEMENT

Last updated: 7 July 2021


This privacy policy applies to Affinity Global Inc. and its performance marketing platform VEVE (collectively, “VEVE,” or “we“, “us“, “our“).

VEVE offers a performance marketing platform to reach consumers through OEMs and browsers. We help driving new customer acquisitions, sales, app downloads and website views through unique formats and media placements.

This Privacy Policy describes how VEVE collects, uses and discloses information, and what choices you have with respect to the information.

Services

VEVE engages with third party publishers to serve ads on their digital properties on behalf of its demand side advertising partners. VEVE also engages in media planning and measurement (e.g. whether an advertisement was viewed, its timestamp etc.)

VEVE provides performance marketing platform Services, including optimization of advertising campaigns, data analytics/enrichment, segment creation, user acquisition or re-engagement through various digital advertising channels. VEVE receives data into its marketing platform from various sources, including end user information collected by our systems, applications, business partners or customers, which may include third party apps and services that you use. Please refer to the privacy policies of the OEMs, apps and services you use to understand how those apps and services collect, use and share data from your interactions with them. VEVE is not responsible for how those third-party services collect and use data.

It is our policy to respect your privacy regarding any information we may collect while using our services and websites, collectively called the Services.

Domains and Websites for this Policy

For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.veve.com as well as the other websites that the Affinity Group operates and that link to this Policy.

Information We Collect

Website user’s Data

When you view an advertisement distributed through VEVE on any digital media, we may collect information on your device and your interaction with the advertisement. This information enables us to serve advertisements to you, improve our Services including to recognize your device when you use other sites and applications that have partnered with us. The information includes:

  • Device identifiers such as iOS devices’ Identifier for Advertising (IDFA) and iOS Identifier for vendors, Google Advertising ID (GAID), or Android ID for Android devices
  • Location information, including
    • Geo-location or precise location of your device if you have given the app or site permission to collect your location information
    • Location information we infer from your device’s IP address
  • Other information such as Device type, Operating System and Language settings

Other Data

Publishers and Advertisers provide data that is necessary to create user accounts.

For creation of user accounts, you provide your name, email address, password, telephone number and correspondence address. You also provide billing details for invoicing purposes.

We also collect data when you use our applications and websites

  • Log Data - Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address
  • Subscription Data – You provide personal data to us as part of signing up for communication from us through our websites. We may also collect personal information from you when you use interactive features of the Websites, promotions, requesting customer support, or otherwise communicating with us.
  • Contact Us Data – When you enquire about our products and services, we collect and store this data to communicate with you and respond to your enquiry.

Cookies

We collect data through cookies 

VEVE uses cookies to identify and track visitors, their usage of website, and their website access preferences. VEVE visitors can control cookies through cookie preference.

For more details about how we use these technologies, please see our Cookie Policy.

Click here to view the Cookie Declaration.

How We Use Your Data

How we use your personal data will depend on which Services you use and how you use those Services.

We use the ‘Website user’s Data’ that we collect about your device to:

  • Display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations
  • For tracking the number of clicks an ad receives 
  • For tracking if you are navigating between two sites
  • For bidding to serve advertisements and to determine which ads are most effective
  • To analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person.
  • For pushing the notifications based on the consent you have given to our publishers such as browsers or devices
  • For pushing the notifications based on the consent you have given to us when we act as publishers
  • To detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems
  • For redirect tracking
  • Internal reporting

‘Other Data’ is used by us to provide our services, send our newsletters and to communicate with you by responding to your requests, comments and questions.

Lawful bases for processing

We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the Data Protection Regulations.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

Where you have consented to a particular processing, you have a right to withdraw the consent at any time.

Users under 16 years of age

The Sites and Services do not knowingly collect personal information from users under the age of 16

If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

Data Retention Policy

Website user’s Data:

We will retain information collected in the context of our Marketing Platform for a period of up to 3 years, unless otherwise required by law or applicable contract.

We may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations.

After the applicable retention period, we may only retain and use your data:

  1. in an aggregated or anonymized format;
  2. to comply with its legal obligations;
  3. to resolve disputes and enforce agreements.

Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.

Other Data

VEVE may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy

Your Rights

You can request to access, update or correct your personal information. You also have the right to object to direct marketing.

You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.

Your Rights to Control Data

Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to or restrict use of your personal information

We strive to give you ways to access, update/modify your data quickly or to delete it unless we have to keep that information for legal purposes. For our website visitors and business partners, these rights can be exercised by contacting us with your specific request.

  • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
  • Delete Data:  You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to provide Services to you).
  • Object to, or Limit or Restrict, Use of Data:  You can ask us to stop using all or some of your personal data (e.g. if we have no legal right to keep using it) or to limit our use of it (e.g. if your personal data is inaccurate or unlawfully held).
  • Right to Access and/or Take Your Data:  You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

Website user’s rights

We provide same rights to the users of our services. We receive requests related to Website user’s rights from our publishers and advertisers.

Account Closure

We keep some personal data even after account closure

Once you choose to close your account, we generally delete your personal information within 3 years of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained as necessary.

Your information shared with others

Recipients of your data

VEVE may share the Website user’s data we collect or receive about you as described in this Policy as follows:

  • Publishers and Supply Partners. We may share your information with publishers (the app or site publishers) to help them understand how users interact with their apps and sites and advertisements on their apps and sites.
  • Demand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings
  • Marketing Partners. We may share your information with data partners who help us with better understanding your preferences by providing data enrichment services and measurement companies who help us with attribution and tracking of advertisements distributed through us ( “Marketing Partners”)
  • Content Providers. We may share personal information we collect about you with our content providers who provide content to be displayed on our websites.
  • Service Providers. We may share personal information we collect about you with our third- party service providers. The categories of service providers to whom we entrust personal information include: IT and related services such as cloud-based data centers, analytics service providers; service providers for fraud detection; CRM and email marketing services.
  • Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity
  • Disclosures in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Cross-Border Data Transfers

Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region

Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centers in Europe and India as well as Affinity data center in USA. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer.

VEVE offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our publishers and advertisers that operate in the European Union, and other international transfers of data. These clauses are contractual commitments between parties transferring personal data (for example, between VEVE and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.

Security Measures to Protect your Data

Security Measures

We implement security controls to prevent breaches and unauthorised access to your data.

We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Examples of security measures include physical access controls, restricted access to data, monitoring for threats and vulnerabilities etc.

Protection of personal information

Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information

VEVE takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

Other Information

Contact Information

You can contact us about this privacy policy or use of our services.

If you have questions or complaints regarding this Policy, you may contact us through email at compliance@affinity.com. You may contact us at our mailing address below

20 N. Wacker Drive, 12th Floor,
Chicago, IL 60606

If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.

Privacy policy change

VEVE may change this Privacy Policy from time to time, at our sole discretion.

VEVE encourages visitors and customers to frequently check this page for any changes to its Privacy Policy. We will notify you of material changes in advance by email or by notice when you log in to the Sites and Services or both. You confirm that your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such changes and agree to be subject to the revised privacy policy.

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