Adspur Privacy Notice


Adspur Privacy Notice

Introduction

This Privacy Notice provides our policies and procedures for collecting, using and disclosing your information. We are Adspur Limited, a privately-owned limited company registered in the UK. Currently users can access the Adspur Service (the “Service”) through our website www.adspur.com. This Privacy Notice governs your access of the Adspur Service and by using the Service you consent to the collection, transfer, processing, storage, disclosure and other uses of Personal Information as described in this Privacy Notice (together with any other terms of use or documents referred to herein).  Personal Information and Personal Data are terms used in this Privacy Notice, both of which refer to any information relating to an identified or identifiable individual. Adspur is committed to ensuring that it collects, uses, shares and otherwise processes Personal Information in accordance with this notice. This includes, in relation to a customer or prospective or former customer of Adspur, as well as any member of staff accessing or using the Adspur Service on behalf of a client.

Data Protection Officer contact details

Adspur’s global headquarters is based in London, United Kingdom. We have appointed a Data Protection Officer for you to contact if you have any questions or concerns about our Personal Information policies or practices. Adspur’s Data Protection Officer and contact information are as follows:

Data Protection Officer
Adspur
58/60 Fitzroy Street
London
W1T 5BU
Email: dataofficer@adspur.com

What Personal Information does Adspur collect?

Adspur collects Personal Information from various sources, including:

  • Information you voluntarily provide, such as your name and email address;
  • Information automatically collected when you use our Sites and Services. This is collectively known as Log Data;
  • Information collected by cookies and other tracking technologies when you use our Site. Read more about our cookie policy here; and
  • Information collected from third parties, such as our payment partner WorldPay on whether a payment was successful or failed.

This Personal Information may include:

  • Contact information
  • Demographic information
  • Payment transaction result information (success or fail)
  • Technical information

How do we use Personal Information?

Adspur uses Personal Information for purposes that are appropriate, based on legitimate interests or as authorized by applicable law. These purposes may include:

Legal, regulatory or law enforcement purposes:

  • Comply with local and national laws;
  • Enforce our legal rights and satisfy our legal obligations, including, without limitation, any reporting or disclosure obligations under applicable law or regulations or subpoena, court order or other judicial or administrative process, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others;
  • Conduct our own due diligence checks;
  • Prevent, detect and prosecute fraud or crime or to assist others in doing so;
  • Assist in investigation by Adspur, other organizations or third parties of suspected criminal activity;
  • Carry out obligations arising from any contracts entered into between you and Adspur;
  • Manage and enforce Adspur’s rights, terms of use or any other contracts with you and your business;
  • Assess financial and insurance risks;
  • Notify you about important changes or developments to Adspur’s website or our goods and services;
  • Identify and monitor for fraud;
  • Maintain internal recordkeeping and reporting;
  • Prepare and furnish compilations and analyses as well as other reports of aggregated and anonymized information;

HR purposes:

  • Process your job application if you apply for a job vacancy at Adspur; and
  • Maintain internal recordkeeping and reporting.

Security purposes:

  • Conduct our own due diligence checks;
  • Administer Adspur’s Site and Services for internal operations, including troubleshooting;
  • Keep Adspur’s Sites and Services safe and secure;
  • Maintain internal recordkeeping and reporting;
  • Identify and monitor for fraud; and
  • Mitigate information security, sector or other risk.

Marketing purposes:

  • Marketing or market research;
  • Perform analysis and comparisons;
  • Maintain internal recordkeeping and reporting;
  • Improve and develop Adspur’s business;
  • Provide information about products and services you requested, purchased or which may be of interest to you to;
  • Provide or develop more innovative and effective Adspur services for our customers;
  • When Adspur communicates with you or each other;
  • Enable contest, promotion or survey entries;
  • Create profiles and marketing opportunities;
  • Create promotional materials for future events and distribute to event participants;
  • Social media site integration and interaction;
  • Optimize Adspur’s websites/portals, products and services;
  • Notify you about important changes or developments to Adspur’s Sites and Services;
  • Improve Adspur’s Sites and Services, and ensure content is presented in effective way; and
  • Allow you to participate in interactive features of Adspur’s service;

Product development purposes:

  • Provide or develop more innovative, user friendly and effective products and services;
  • Maintain internal recordkeeping and reporting;
  • Prepare and furnish compilations and analyses as well as other reports of aggregated and anonymized information;
  • Commercial purposes, such as trend analysis and the use of data analytics to obtain learnings and insight around cardholder transaction patterns and usage; and

Customer Services/Account Management purposes:

  • Enable you to contact us;
  • Provide training;
  • Provide or develop more innovative and effective Adspur services for our customers;
  • Authorize and establish agency and network accounts;
  • Maintain internal recordkeeping and reporting;
  • Enable you to upload and/or store information;
  • Information, products and services you requested, purchased or which may be of interest to you;
  • Enable you to participate in any social media functions on Adspur’s site;
  • Manage, investigate and resolve complaints;
  • Allow you to participate in interactive features of Adspur’s service;
  • Respond to any inquires;
  • Enable you to enter a competition, promotion or survey;
  • Provide Adspur Services to you and your business;
  • Enable you to report a problem with Adspur’s site;
  • Subscribe you to an Adspur service;
  • Register your use of any Adspur Services;
  • Understand Adspur’s customers' requirements; and
  • Notify you about important changes or developments to Adspur’s website or services.

Who do we share Personal Information with and for what purposes?

We will store and display your Personal Information in your profile page and elsewhere on the Service according to the preferences you set in your account. You can review and revise your profile information at any time. We do not sell your personal information to third parties. We may also share or disclose your information with your consent.

Before we share Personal Information, we ensure there are adequate safeguards in place to protect the processing of that data. Except where permitted, Adspur does not sell, rent, share or otherwise disclose Personal Information to third parties for the third party’s commercial purposes.

Adspur does not disclose information that could identify you personally to anyone, except as described in this notice, including, but not limited to:

  • Any Adspur group company;
  • Any group company (such as advisers, share plan, payroll and other third-party administrators, agents or contractors working on behalf of Adspur);
  • Financial institution clients;
  • Service providers and other third parties under contract who help with our business operations (including, but not limited to, fraud investigations, site analytics and operations);
  • Social media sites integrated into web services that we offer;
  • Governmental or quasi-governmental organizations; and
  • Potential purchasers of Adspur.

Adspur may disclose Personal Information to third parties for the following purposes:

Legal or regulatory purposes, including:

  • Where Adspur are required or permitted to do so by law or regulations, including for tax purposes or to comply with financial services regulations;
  • Where Adspur deem it in the national interest or otherwise lawful to do so;
  • In the course of litigation;
  • Following requests from governmental or public authorities;
  • National security;
  • As part of a legal process; and
  • When we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Business purposes, including:

  • Improve and develop Adspur’s business;
  • Business partners (including those in which Adspur has an investment), suppliers and sub-contractors for the performance of any contract Adspur may enter into with them or you;
  • Transfer information and/or assets in the event of a merger, acquisition, sale, bankruptcy filing, or other corporate restructuring;
  • If Adspur or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets; and
  • If Adspur sells or buys any business or assets, in which case Adspur may disclose your Personal Information to the prospective seller or buyer of such business or assets.

Suppliers who assist Adspur with the provision of its services, including:

  • Fulfilling or providing services we use, such as hosting;
  • Processing payments;
  • Managing credit, security, sector and fraud risk;
  • Market research; and
  • Survey activities.

Adspur may use certain trusted third-party companies and individuals to help us provide, analyze, and improve the Service (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Service’s features). These third parties may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. As of the date this policy went into effect, we use Amazon’s S3 storage service to store your data. You can find more information on Amazon's data security from the S3 site. We also use WorldPay to handle and process subscription actions. You can find out more data security information from WorldPay’s website.

Information on cross-border data transfers

Adspur has its headquarters in London, United Kingdom. Information Adspur collects from you may be transferred, stored and processed in a country different from where the data was collected or outside of the European Economic Area (“EEA”), for example, data collected from within the EEA may be stored or processed in the United States or data collected from the United States may be stored or processed in India or Asia Pacific.

Adspur’s eCommerce supplier, WorldPay, complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data received from the European Union (EU) and Switzerland to the United States. Please click here to view Worldpay’s eCommerce Privacy Shield Policy.

Individual’s Privacy Rights (data subject rights)

Under the EU’s General Data Protection Regulation, individuals located in Europe are able to exercise rights regarding their Personal Information. You can find a more detailed summary of these rights on the Information Commissioner’s Office’s website here. These rights include:

  • the right to access;
  • the right to rectification;
  • the right to restriction;
  • the right to erasure;
  • the right to object; and
  • the right to data portability.

If access cannot be provided within a reasonable time frame, Adspur will provide you with a date when the information will be provided. If for some reason access is denied, Adspur will provide an explanation as to why access has been denied.

Individuals in Andorra, Argentina, Australia, Canada, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Uruguay, and certain other jurisdictions may also exercise these or similar rights.

California’s “Shine The Light” law permits California residents free of charge to annually request and obtain a list of certain categories of Personal Information disclosed to third- parties for direct marketing purposes in the preceding calendar year and the names and addresses of such third parties and such further information sufficient to give the customer a reasonable indication of the nature of the third parties' business. Please send any such request to the contact address below, and Adspur will respond within 30 days.

The laws of other territories applicable to your dealings with Adspur may also be relevant (and may also impact the above rights). Any such rights can be progressed through our customer services center or via the ‘contact us’ section below.

Adspur’s GDPR ICO Certificate number is ZA019919, more information can be found here.

How does Adspur ensure the security of Personal Information?

Adspur works to maintain your confidence and trust in us and has therefore implemented physical, technical, and administrative measures designed to secure Personal Information from accidental loss, unauthorized access, use, alteration and disclosure. However, the safety and security of your information is also dependent upon you. We store and process your information on our servers located within the EU (Ireland) and the United States and use other computing facilities around the globe.

Where Adspur has given you (or where you have chosen) a password or access code which enables you to access certain parts of Adspur’s website and similar, you are responsible for keeping this password and/or access code confidential. You should not share your password or access code with anyone and you should use all reasonable methods to ensure that there is no unauthorized use. You therefore authorize Adspur to act upon instructions and information received from any person that enters your user ID and password and you agree to be fully responsible for all use and any actions that may take place during the use of your account. You also agree to promptly notify Adspur of any information you have provided which has changed.

Unfortunately, the transmission of information via the internet is not completely secure. Although Adspur will take reasonable steps to protect your Personal Information, Adspur cannot guarantee the security of your data transmitted to Adspur’s site; any transmission is at your own risk.

Adspur maintains security standards that are designed to protect your information as it is transmitted from your computer to our network. This technology is called Secure Socket Layer (SSL). SSL is a leading security protocol for data transfer on the Internet and helps to protect the safety and confidentiality of your online banking information.

You have a role in helping Adspur by safeguarding your information from others. You have several options when deciding how you can best protect your Personal Information. One option is simply not to volunteer it. The Federal Trade Commission’s websites (www.ftc.govwww.ftc.gov/idtheft, and www.onguardonline.gov) offer useful information about how to protect your Personal Information.

How long does Adspur store and retain Personal Information?

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, you may delete your account here. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.

Changes and updates to the privacy notice

Adspur may, from time to time, make changes to this Privacy Notice. If any material changes are made as to how Adspur treat Personal Information, you will be notified through this notice on Adspur’s Sites and Services.

The date the Privacy Notice was last modified is at the bottom of the page. You are responsible for ensuring you periodically visit our Sites and Services and Privacy Notice to check for any changes. By continuing to use Adspur Services, you agree to the changes in this Privacy Notice.

This notice is global in scope but is not intended to override any legal rights in any territory where such rights prevail. In such event, the rights and obligations set out in this Privacy Notice will apply, subject only to amendment under any applicable local law having precedence.

Any questions?

All comments, queries and requests relating to Adspur’s use of Personal Information are welcomed. Please contact our Data Protection Officer:

Data Protection Officer 
Adspur
58/60 Fitzroy Street
London
W1T 5BU
dataofficer@adpur.com

If you are in the United Kingdom and have any queries or complaints about the processing of your Personal Information, you can also contact the Information Commissioner’s Office here.

If you are in the United States and have any queries or complaints about the processing of your Personal Information, you can also contact the Federal Trade Commission here.

Updated: 10/22/2018