Privacy Policy of the GiftPanda Services of the ayeT-Studios GmbH

The ayeT-Studios GmbH and its Supply Brands CashPirate, GiftPanda and CashMiner, d/b/a “ayeT-Studios” and any future corporate affiliates (collectively, “ayeT-Studios”) put great efforts in making sure that personal information is safe and used only in full compliance with applicable data protection laws and regulations.

This privacy policy (“Policy”) explains ayeT-Studios’ privacy practices for processing personal information on ayeT-Studios’ websites and apps (the “Sites & Apps”) and via ayeT-Studios’ Services (the “Services”). It applies whenever you access or use the Sites & Apps or a mobile application or website that is connected and/or uses the Services (as applicable). Please take the time to read the full Policy.


I. The ayeT-Studios Sites & Apps Privacy Policy


1. Intro to the ayeT-Studios Sites & Mobile applications

The ayeT-Studios Sites & Apps (Mobile Applications) are marketing websites and apps aimed to provide information and content, created by ayeT-Studios, about ayeT-Studios and its Services. The ayeT-Studios Sites & Apps include, but are not limited to the following:

Corporate website:
www.ayetstudios.com

Reward Platforms:
www.cashpirate.mobi
www.giftpanda.mobi
www.giftpanda.de
www.gift-panda.com
www.gift-panda.in

Apps:
https://play.google.com/store/apps/details?id=com.ayet.cashpirate
https://play.google.com/store/apps/details?id=com.giftpanda
https://play.google.com/store/apps/details?id=com.ayet.cashminer

You may visit the ayeT-Studios Sites & Apps without any registration.

When visiting the Sites & Apps, ayeT-Studios may receive information that you voluntarily provide, such as when you fill out a “contact us” form request, when you apply to join one or more of the ayeT-Studios Services or when you subscribe to the ayeT-Studios newsletter and may collect certain ‘traffic/session’ information from your device. Such information may include personal information such as your name, email address, telephone number or any other information you provide to ayeT-Studios. Please note that you are not required by law to provide us personal information. Our Sites & Apps are not directed to children under 16 years of age and we do not intentionally or knowingly collect personal information on such users


2. The Personal Information that ayeT-Studios collects and Personal Information You Provide voluntarily via the Sites & Apps

Depending on how you interact with ayeT-Studios’ Sites & Apps, collection and processing of personal data varies.

a) When you contact ayeT-Studios, by filling a form on the Sites & Apps, contacting ayeT-Studios’ customer support team for technical issues or contacting ayeT-Studios’ legal team with any questions or inquiries or when ayeT-Studios contacts you regarding any of the above, ayeT-Studios may receive and process any personal information that you provide ayeT-Studios such as your name, your company’s name and email address.

If you submit personal information in a comment on a blog post or on any applicable social media websites, the personal information that you submit can be read, collected or used by others and could be used to send you unsolicited messages or otherwise contact you. ayeT-Studios is not responsible for the personal information that you choose to submit in these blogs.

ayeT-Studios may use the information you provide via the Sites & Apps for its business’ purposes, such as responding to your inquiries or support requests, for marketing, recruiting and hiring, and to contact you in the course of offering you with any of the Services and/or with the ayeT-Studios newsletter. ayeT-Studios retains the information collected via the Sites & Apps for so long as you use the Services or until you choose to unsubscribe from the ayeT-Studios mailing list (link to cancel subscription is included in every email sent to you), or until ayeT-Studios deletes your personal information pursuant to a written request from you.

When you access the corporate website, ayeT-Studios’ servers log certain ‘traffic/session’ information from your device, such as your user agent and the Internet Protocol (IP) address. ayeT-Studios may collect information about your activity, for example, your log-in and log-out time, the duration of sessions, viewed web-pages or specific content on web-pages, activity measures and geo-location of your device.

ayeT-Studios may use the information collected on the Sites & Apps to evaluate Users’ interests and behavior on a pseudonymous, no-name basis in order to being able to deliver tailored content.

As required under applicable law, ayeT-Studios will use identifiable information to enforce ayeT-Studios’ terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, and to take any action in any legal dispute and proceeding.

ayeT-Studios commits to process personal information solely for the purposes described in this policy.

b) In case you register for an account in one of the Sites (reward platforms) & Apps, we receive and collect information about you, your device and the ad offers that you view and engage with, and we use this information to provide and improve the services, reward you for offer engagement, and to draw inferences about which offers may be more or less interesting to you. This information is collected through the Sites & Apps, and through your interactions with ads.

Here are the types of information that we may collect from you:
- Device identifiers (a device identifier is a string of numbers and letters unique to your smartphone or tablet assigned by the manufacturer or platform provider), such as
- Google Advertising ID (GAID), or Android ID in its absence (or MAC address, in the absence of both), for Android devices
- ID for Advertisers (IDFA), for iOS devices
- Information about the device itself, including
- Whether it is a smartphone or tablet
- What operating system and version it uses (e.g., iOS, version 11.0)
- Model and manufacturer (e.g., Apple iPhone X, Samsung Galaxy S8)
- User agent
- Battery fill and temperature
- System uptime
- Screen size, screen density, and other information relevant to ad formatting and display
- Memory and CPU information
- Information about the internet connection used to access our services, including
- Mobile carrier
- Network provider
- Network type (e.g,. wifi)
- IP address
- Timestamp and duration (i.e., when the device connected to our services began and how long the connection lasted, for a given session)
- Location-related information
- We infer the perceived general location of the device based on:
- The IP address used to access our services
- Location-related device settings, such as the device’s country code, language setting
- Ad-related information - We collect information about the ads you view, such as:
- What the ad offer is about;
- What type of ad it is (e.g., text, image, or video);
- Which ad placement is involved (i.e., where the ad offer is displayed within the mobile app in which you accessed it); and
- Whether you respond to the ad’s “call to action” - for example, did you click through to the advertiser’s website?
- Payment handling information - If you opt for a payout in one of the reward platforms or Apps you also opt to provide your email address or PayPal account address for ayeT-Studios to be able to send your reward. To ensure greater security, ayeT-Studios shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment
- Registration and authentication - By registering or authenticating, You allow ayeT-Studios to identify you and give you access to dedicated services. Depending on your selected registration / authentication method, third parties (as laid out in section 3 of this policy) may provide registration and authentication services. In this case, this Sites & Apps will be able to access some Data, stored by these third party services, for registration or identification purposes.
- Survey information - We occasionally run ad offers for demographic surveys so we can identify client survey opportunities that you may be eligible for through the Third Party Market Research (MR) companies. If you opt to complete one of these surveys, we associate the responses with the device identifier for the device you used to access and complete the survey offer. ayeT-Studios may share your personal information and/or social-demographic information, including, without limitation, a unique identification number (“UID”), postal code, region, province, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information, non-personally identifiable information on household members, consumer product and service usage and ownership (e.g., computers, cars, mobile devices, video games, etc.), home ownership, pet ownership, employment information (e.g., title, role, travel, industry, etc.), and social grade, with third party sample/market research companies (individually each a “Third Party MR Company” and collectively the “Third Party MR Companies”) for the following purposes:
- Identifying client survey opportunities that you may be eligible for through the Third Party MR Companies; and
- Disclosing such data elements to clients of the Third Party MR Companies for audience measurement services; and
- Appending such data elements to completed client surveys and delivering the appended survey data to clients of the Third Party MR Company(ies) for analytical or research purposes; and
- Other uses as set forth in their privacy policy.
If you are eligible for a client survey opportunity offered through a Third Party MR Company, the Third Party MR Company will provide your unique identification number and a survey link to us and we will invite you to participate in the client survey through our incentivized offer walls. We will not share your name, email address, or phone number with the Third Party MR Companies. In connection with the sharing of your information with a Third Party MR Company, your information may be transferred and stored outside of your country of residence, including, without limitation, in the United States, and by agreeing to this privacy policy you are agreeing to the processing and exportation of your personal information as set forth in this Section. If you complete one of those surveys, your responses go to the MR company (not to us), and will be governed by the MR company’s privacy policy. If you have any questions about this data sharing or if you want to opt-out, please contact privacy@ayetstudios.com. If you opt-out, it is the responsibility of us to inform the Third Party MR Companies. Please note that ayeT-Studios is solely liable and responsible for managing all opt-out requests. Your participation in such survey opportunities does not entitle you to any benefits offered by, or membership with, the Third Party MR Companies.
Unless specified otherwise, all Data requested is mandatory and failure to provide this Data may make it impossible for this Sites & Apps to provide its services. In cases where this Sites & Apps specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.



3. The Sites & Apps may include Third Party Services

Third party’s services are incorporated in the Sites & Apps but are governed by their respective privacy policy. ayeT-Studios therefore encourages you to read these privacy policies before using the Sites & Apps. A full overview of all Services used on the Sites & Apps can be found here:

for ayeT-Studios Sites:
www.ayetstudios.com: https://builtwith.com/ayetstudios.com
www.cashpirate.mobi: https://builtwith.com/cashpirate.mobi
www.giftpanda.mobi: https://builtwith.com/giftpanda.mobi
www.giftpanda.de: https://builtwith.com/giftpanda.de
www.gift-panda.com: https://builtwith.com/gift-panda.com
www.gift-panda.in: https://builtwith.com/gift-panda.in

for ayeT-Studios Apps:
https://play.google.com/store/apps/details?id=com.ayet.cashpirate
https://play.google.com/store/apps/details?id=com.giftpanda
https://play.google.com/store/apps/details?id=com.ayet.cashminer

Third Party Services may include

- Facebook Authentication
- Google OAuth
- Crashlytics
- Google Analytics
- Google Firebase
- Appsflyer
- PayPal
- Trialpay
- Fyber
- AdColony

ayeT-Studios Sites & Apps may include links to third-party social media websites, such as Youtube, Facebook, Twitter, LinkedIn, Google+ and Vimeo, as well as associated social media features and scripts, such as the Facebook “like” button and widgets. These features and scripts may collect your IP address, which page you are visiting on the Sites & Apps, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by the applicable third party social media website or hosted directly on the Sites & Apps.

Your interactions with these social media features and widgets, as well as your interactions with the social media websites themselves, are governed by the privacy policies of the applicable social media websites.


4. Sharing Personal Information with Others

ayeT-Studios may share your personal information with service providers and other third parties, if necessary to fulfill the purposes for collecting the information, provided that any such third party will commit to protect your privacy as required under the applicable law and this policy.

ayeT-Studios may share Personal Information with ayeT-Studios’ corporate affiliates in order to operate the Sites & Apps.

ayeT-Studios may share Personal Information with law enforcement and/or government agencies, courts, and/or other organizations: (a) as required by law, such as to comply with a subpoena, or similar legal process; and/or (b) when ayeT-Studios believes in good faith that disclosure/sharing is necessary to protect ayeT-Studios’ rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

ayeT-Studios may share or transfer Personal Information if ayeT-Studios is involved in a merger, acquisition, or sale of all or a portion of its assets, as part of such transaction. You will be notified via a prominent notice on the Sites & Apps of any change in ownership or uses of this information if applicable. In any event, your information will remain protected under this Policy.

ayeT-Studios may share it in any other circumstances where ayeT-Studios receives your written consent.


5. Aggregated and Analytical Information

ayeT-Studios may also collect information that is non-identifiable to you through Google Analytics, such as the type of browser, browser language, type of operating system, domain name of Internet service provider, device IP address web pages visited, times and dates of visits and the content you access on and/or via the Sites & Apps.

ayeT-Studios uses the standard analytics tools such as
- Google Analytics
- Google Firebase
- Facebook
- Appsflyer

and may use additional or other analytics tools, from time to time.
The privacy practices of these tools are subject to their own privacy policies and can be found here:
Google Analytics: http://www.google.com/analytics/learn/privacy.html
Google Firebase: https://policies.google.com/privacy
Facebook: https://developers.facebook.com/
Appsflyer: https://www.appsflyer.com/privacy-policy/

ayeT-Studios uses anonymous, statistical or aggregated information and may share them with ayeT-Studios’ partners for legitimate business purposes. This has no effect on your privacy because there is no reasonable way to extract data from the aggregated information that can be associated with you.


6. Cookies

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie.

ayeT-Studios uses Session Cookies for legitimate purposes, such as facilitation of the use of the Sites & Apps and its features and tools. By using our Sites & Apps, you accept our use of cookies. You may manage your cookies preferences through the setting of your browser.


7. User Choice

If you have an account in the Sites & Apps, at any time, you may disable your account through your account page or by sending an opt-out or account deletion request to: support@ayetstudios.com. Thereafter, ayeT-Studios will stop collecting any personal information from you.

At any time, you may unsubscribe from ayeT-Studios’ newsletters list, by sending ayeT-Studios an opt-out request to: support@ayetstudios.com or clicking the “unsubscribe” link available thereto.

You may manage your cookies preferences through the setting of your browser.


8. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personal information relating to third parties to which ayeT-Studios has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes.

To make such a request, please contact ayeT-Studios at: privacy@ayetstudios.com


9. Accessing Your Personal Information

At any time, you may contact ayeT-Studios at: privacy@ayetstudios.com and request to access the personal information that ayeT-Studios keeps on you. ayeT-Studios may need to ask you to provide certain credentials to make sure that you are who you claim to be. If you find that the information on your account is not accurate, complete or updated, then please provide ayeT-Studios the necessary information to correct it.

At any time, you may contact ayeT-Studios at: privacy@ayetstudios.com to receive a copy of the personal information that ayeT-Studios keeps about you, and to verify the accuracy of the data.

If you’d like ayeT-Studios to delete data that you have provided via the Sites & Apps, please contact ayeT-Studios at privacy@ayetstudios.com and ayeT-Studios will respond in a reasonable time.

Please be advised that ayeT-Studios may retain and use your personal information as necessary to comply with its legal obligations, resolve disputes and enforce ayeT-Studios’ agreements.

In addition, after ayeT-Studios deletes your personal information, residual copies may take a period of time before they are deleted from ayeT-Studios’ active servers and may remain in its backup systems.

This deletion will not change or delete personal information which may have already been shared with third parties, as permitted in this Policy or any other agreement between you and ayeT-Studios.

ayeT-Studios may redact from the data which it will make available to you, any personal information related to others.


10. Your EU Data Subject Rights

In operating the Sites & Apps, ayeT-Studios processes data as a controller (as such terms are defined in the GDPR). As a controller, ayeT-Studios is committed to fulfill data subjects’ (‘Users’) GDPR rights.

As an EU resident, you may

- Access the data that ayeT-Studios keeps about you. ayeT-Studios may need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete or updated, then you may provide us with the necessary information to rectify it.
- Contact us if you want to withdraw your consent to the processing of your personal information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
- Request to delete or restrict access to your personal information. ayeT-Studios may postpone or deny your request if your personal information is in current use for providing the Services or due to other legitimate purposes, such as compliance with regulatory requirements associated with ayeT-Studios.

If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your personal information, in accordance with this Policy, will act accordingly.
- You may ask to transfer your personal information in accordance with your right to data portability.
- You may object to the processing of your personal information for direct marketing purposes.
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
- You have a right to lodge a complaint with a data protection supervisory authority.

  • ayeT-Studios does periodical assessments of its data processing and privacy practices, to make sure that ayeT-Studios complies with this policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible.
  • If you have any concerns about the way ayeT-Studios process your personal information, you are welcome to contact ayeT-Studios’ data protection officer at:
  • privacy@ayetstudios.com
  • or write to ayeT-Studios to:
  • ayeT-Studios GmbH
  • Lister Platz 2
  • 30163 Hannover
  • Germany
  • ayeT-Studios will look into your enquiry and make good-faith efforts to resolve any existing or potential dispute with you. If you remain unhappy with the response you received, you can also refer the matter to the data protection authorities in Germany.


11. Data Retention

ayeT-Studios stores and retains your personal information for as long as you use the Sites & Apps and/or remain subscribed to the ayeT-Studios newsletter or blog. Notwithstanding the foregoing, ayeT-Studios may store and retain your personal information for a reasonable time of up to 90 days after you stopped using the Sites & Apps and/or unsubscribed to the ayeT-Studios newsletter or blog for internal reporting and analytics and improving the Sites & Apps and/or any product or services provided thereto.

ayeT-Studios may retain various types of information for longer periods pursuant to legal requirements under the applicable law.

ayeT-Studios will make efforts to guarantee that personal information is kept for no longer than is necessary for the purposes for which the personal information is processed.

In any case, as long as ayeT-Studios uses your personal information to provide the Services, ayeT-Studios will retain the personal information about you, unless ayeT-Studios is required by law to delete it, or if ayeT-Studios accepts your request to delete the information, pursuant to applicable laws, or if ayeT-Studios decides to remove it at its discretion.


12. Transfer of data outside your territory

ayeT-Studios may store and process information in various sites throughout the globe, including in sites operated and maintained by cloud based service providers, as currently described in its list of sub-processors listed here:

Software & Server Providers:

- Zendesk
- Salesforce
- Mailchimp
- Userlike
- Disqus
- Microsoft
- Google
- Amazon AWS
- Server4You
- Serverloft


Analytics Providers:

- Appsflyer
- Google Analytics
- Google Firebase

Monetization Providers:
- Fyber
- AdColony
- Trialpay

If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you hereby provide ayeT-Studios your express and unambiguous consent to such transfer or by using the Sites & Apps you hereby provide your express consent to such transfer (as applicable).

If you are a resident of the European Economic Area (EEA), your personal information is processed and stored by Amazon Web Services (AWS) Cloud in the US on ayeT-Studios’ behalf in accordance with the highest degree of security of AWS.


13. Information Security

ayeT-Studios is concerned about safeguarding the confidentiality of your personal information. ayeT-Studios and its hosting services implement systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

For example, ayeT-Studios limits access to this information to authorized personnel who need to know that information in order to operate, develop or improve the Sites & Apps.

These measures provide sound industry standard security. However, although ayeT-Studios makes efforts to protect your privacy, ayeT-Studios cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.


14. Changes to this Privacy Policy

From time to time, ayeT-Studios may update this policy. If the updates have minor if any consequences, they will take effect 7 days after ayeT-Studios posts a notice on the Sites & Apps. Substantial changes will be effective 30 days after ayeT-Studios’ notice was initially posted.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Sites & Apps. Continuing to use the Sites & Apps after the new policy takes effect means that you agree to the new policy.

Note that if ayeT-Studios needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.


15. Contact ayeT-Studios

Please contact ayeT-Studios’ Data Protection Officer at: privacy@ayetstudios.com for further information.


Last Updated: May 24, 2018

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II. The ayeT-Studios Services Privacy Policy

ayeT-Studios develops and operates several services in the ad-tech environment, such as a mediation platform, programmatic mediation platform, incentivized offer walls, direct sales service and other online advertising-related services, all of which may include advertising management services, such as optimization, ad serving, campaign management and the compilation of relevant statistical data (collectively, the “Services”).

This Policy explains ayeT-Studios’ privacy practices for processing personal information via the Services and it applies whenever you access or use the Property of a Supply Partner that is connected to and/or uses the Services. Our Services are not directed to children under 16 years of age and we do not intentionally or knowingly collect personal information on such users.


1. The Services

ayeT-Studios provides advertisers, agencies, DSPs and/or ad networks (collectively, “Demand Partners”) and website and/or mobile application/website developers and/or owners and/or publishers (collectively, “Supply Partners”; Supply Partner and Demand Partners are also referred to hereinafter as “Customers”) with the following Services:

- Mediation service, that enables Supply Partners to optimize placement of ads by third-party Demand Partners on their website or mobile application/website (“Property”) and for Demand Partners to buy ad inventory and serve ads directly on such Property;
- Programmatic Mediation service, that enables Supply Partners and Demand Partners to use programmatic auction for the sale and purchase of advertising space inventory on the Property;
- Offer Wall service, that enables Supply Partners and Demand Partners to use an opt-in scrollable offers which includes individual Ads to integrate into Property.
- Direct Sales service, that enables Supply Partners and Demand Partners to run ad campaigns on certain Property.
- From time to time, ayeT-Studios may offer ancillary services to the services described above and additional services.
- ayeT-Studios has no direct interaction with the individuals that visit Customers’ services (“Users”), except for the ayeT-Studios Offer Wall service where ayeT-Studios provides technical support only in behalf of Supply Partner to Users of the Offer Wall.
- ayeT-Studios’ Customers are required to provide an adequate notice to Users about this Privacy Policy and to provide a privacy policy of their own, as required by the applicable legislation.



2. The Personal Information that ayeT-Studios collects and receives

ayeT-Studios collects personal information in order to provide the Services and for other specific purposes, as described in this Privacy Policy. Please note that you are not required by law to provide ayeT-Studios with any personal information.

ayeT-Studios only collects information that the Supply Partner had instructed ayeT-Studios to collect, in writing, prior to such collection, and subject to your permissions inside the Property and/or your mobile device.

As an example, ayeT-Studios’ Software Development Kit (“SDK”) that may be installed on the Property you are using will not collect your location data unless you affirmatively allowed/enabled the Property to collect it. Other information may be received via an API integration between ayeT-Studios’ server and trusted third-party’s servers and additional information may be received by embedding tags on websites you visit.

From time to time, ayeT-Studios may use additional or alternative tools to collect information, in which case this Privacy Policy will be amended accordingly. When interacting with the Property, ayeT-Studios may collect/receive the following information:

- Information about your device, such as device type and model, network provider, browser type, language.
- Information about the Property, such as package name, keywords, version.
- Information about your operating system, such as Android, iOS.
- Information about your mobile advertising identifiers, such as your Advertising ID (Apple: IDFA or Google: GAID).
- Information provided by your device, such as device IP address, network connection type and device GPS location (only if you provide permission).
- Information ayeT-Studios may receive from Supply Partners, such as your age, gender, zip code, GPS location.
- Information ayeT-Studios may receive from Third Parties about you from sources other than the Property, such as non-precise device location based on IP address, device specifications and User’s interests.
- Demographic and user interest data that you choose to share with us by taking part in surveys or similar. Those data collected through the survey process can be associated with aforementioned data / cookie collected data.

When interacting with the Property and you choose to participate in surveys or similar, ayeT-Studios may collect/receive and share the following information:

- ayeT-Studios may share your personal information and/or social-demographic information, including, without limitation, a unique identification number (“UID”), postal code, region, province, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information, non-personally identifiable information on household members, consumer product and service usage and ownership (e.g., computers, cars, mobile devices, video games, etc.), home ownership, pet ownership, employment information (e.g., title, role, travel, industry, etc.), and social grade, with third party sample/market research companies (individually each a “Third Party MR Company” and collectively the “Third Party MR Companies”) for the following purposes:
- Identifying client survey opportunities that you may be eligible for through the Third Party MR Companies; and
- Disclosing such data elements to clients of the Third Party MR Companies for audience measurement services; and
- Appending such data elements to completed client surveys and delivering the appended survey data to clients of the Third Party MR Company(ies) for analytical or research purposes; and
- Other uses as set forth in their privacy policy.
If you are eligible for a client survey opportunity offered through a Third Party MR Company, the Third Party MR Company will provide your unique identification number and a survey link to us and we will invite you to participate in the client survey through our incentivized offer walls. We will not share your name, email address, or phone number with the Third Party MR Companies. In connection with the sharing of your information with a Third Party MR Company, your information may be transferred and stored outside of your country of residence, including, without limitation, in the United States, and by agreeing to this privacy policy you are agreeing to the processing and exportation of your personal information as set forth in this Section. If you complete one of those surveys, your responses go to the MR company (not to us), and will be governed by the MR company’s privacy policy. If you have any questions about this data sharing or if you want to opt-out, please contact privacy@ayetstudios.com. If you opt-out, it is the responsibility of us to inform the Third Party MR Companies. Please note that ayeT-Studios is solely liable and responsible for managing all opt-out requests. Your participation in such survey opportunities does not entitle you to any benefits offered by, or membership with, the Third Party MR Companies.


3. What does ayeT-Studios do with Personal Information?

ayeT-Studios uses the personal information that it collects and receives -
- to provide the Services;
- to enable and optimize the Services’ tools and features
- to study and analyze the functionality of the Services, Customers’ and Users’ activities,
- to provide support,
- to measure the Services’ activity for pricing purposes,
- to maintain the Services,
- to improve the Services and to continue developing the Services.

ayeT-Studios may use the information collected to evaluate Users’ interests and behavior on a pseudonymous, no-name basis in order to being able to deliver tailored content. If necessary, ayeT-Studios may use identifiable information to enforce its terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, and to take any action in any legal dispute and proceeding.

ayeT-Studios commits to process personal information solely for the purposes described in this policy. To the extent relevant and possible, ayeT-Studios will make efforts to maintain accurate information that is complete and up-to-date.


4. Sharing Personal information with others

ayeT-Studios may share personal information for the following purposes:

Share it with its trusted Demand Partners:
- For the purpose of serving you with contextual and/or targeted ads that are relevant to you and may interest you.
- For ad reporting purposes and for Demand Partners to have information about the performance of their ad campaigns and improve their ads performance over time.

Share it with Supply Partners:

- To help them understand how Users are engaging with ads, what kind of Users are most engaging with certain types of ads on their Property, and what kind of ads are published on their Property;


Share it with Third Parties:

  • - To receive additional data on you from sources other than the Property in order to help analyze and enrich the information collected on you, as well as serve you with more relevant and targeted ads on the Property and elsewhere.
  • - To receive Third Party’s services, such as fraud protection, bot detection, rating, analytics, viewability, geo location services, ad security and verification services.

Share it with ayeT-Studios’ corporate affiliates in order to provide the Services.

Share it with law enforcement and/or government agencies, courts, and/or other organizations: (a) as required by law, such as to comply with a subpoena, or similar legal process; and/or (b) when ayeT-Studios believes in good faith that disclosure/sharing is necessary to protect its rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

Share or transfer it, if ayeT-Studios is involved in a merger, acquisition, or sale of all or a portion of its assets, as part of such transaction. You will be notified via a prominent notice on ayeT-Studios’ website of any change in ownership or uses of this information. In any event, your information will remain protected under this Policy;

Share it in any other circumstances where ayeT-Studios receives your written consent.


5. Aggregated and analytical information

ayeT-Studios may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they may use their own cookies to provide their service (for further information about cookies, please see the ‘Cookies’ section in this policy).

ayeT-Studios uses the standard analytics tools such as:

- Google Analytics
- Google Firebase

and may use additional or other analytics tools, from time to time.
The privacy practices of these tools are subject to their own privacy policies and can be found here:
Google Analytics: http://www.google.com/analytics/learn/privacy.html
Google Firebase: https://policies.google.com/privacy


6. Cookies

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie.

ayeT-Studios uses session cookies for legitimate purposes, such as facilitation of the use of the Property you use and its features and tools. To clarify, ayeT-Studios’ cookies do not collect any personal information about you. When you visit a website, the cookie can recognize your device based on internal identifier of ayeT-Studios’ systems and in the future, if you return to that website, it can read that cookie to remember you from your last visit. By keeping track of you over time, cookies may be used by ayeT-Studios and its Demand Partners Advertisers to deliver ads targeted to you and track your engagement with these ads.

If you wish to delete cookies or limit the kinds of cookies that can be placed on your device you need to check out the settings in your browser, use the ‘Help’ tab or look for settings like ‘Options’ or ‘Privacy.’ From there, you may be able to delete cookies, block them or control when they can be placed.


7. User Choice

If you have an account in the Services, at any time, you may disable your account through your account page or by sending an opt-out or account deletion request to: support@ayetstudios.com. Thereafter, ayeT-Studios will stop collecting any personal information from you.

However, ayeT-Studios may store and continue using or making available certain personal information that is related to you. For further information, please read the Data Retention section in this policy

If you wish to opt-out from collection and use of precise location data for advertising, you can turn location services off through your device settings. The latest versions of iOS and Android allow you to limit which particular applications can access your location information.

You also can limit the use of identifiers for ad targeting on your devices. If you turn on this setting, apps are not permitted to use the advertising identifier to serve consumers targeted ads.

As an example, for iOS, the controls are available through Settings > Privacy > Advertising > Limit Ad Tracking. For Android, Google Settings > Ads > Opt Out of Interest-Based Ads.

Although this tool will limit the use of tracking data for targeting ads, companies may still be able to monitor your app usage for other purposes, such as research, measurement, and fraud prevention.

You can reset the identifiers on your mobile device in the device settings. iOS users can do this by following Settings > Privacy > Advertising > Reset Advertising Identifier. For Android, the path is Google settings > Ads > Reset advertising ID.

Following such restart, the device is harder to associate with past activity, but tracking can start anew using the new advertising identifier.

If you delete all cookies, you’ll also delete the cookies that indicate your preference to opt out of targeted ads. Please note that even if you opt out of targeted advertising, a company may still use cookies for other purposes, such as to limit the number of times you’re shown a particular ad.


8. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personal information relating third parties to which ayeT-Studios has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes.

To make such a request, please contact us at: privacy@ayetstudios.com.


9. Accessing Your Personal Information

At any time, you may contact us at: privacy@ayetstudios.com and request to access the personal information that ayeT-Studios keeps about you. ayeT-Studios may need to ask you to provide it with certain credentials to make sure that you are who you claim you are. If you find that the information on your account is not accurate, complete or updated, then please provide us the necessary information to correct it.

At any time, you may contact ayeT-Studios at: privacy@ayeT-Studios.com and request to access the personal information that ayeT-Studios keeps about you, and to verify the accuracy of the data.

If you’d like us to delete data that you have provided via the Property, please contact ayeT-Studios at: privacy@ayetstudios.com and ayeT-Studios will respond within a reasonable time after receiving your email.

Please be advised that ayeT-Studios may retain and use your personal information as necessary to comply with its legal obligations, resolve disputes and enforce ayeT-Studios’ agreements.

In addition, after ayeT-Studios deletes your personal information, residual copies may take a period of time before they are deleted from ayeT-Studios’ active servers and may remain in ayeT-Studios’ backup systems.

ayeT-Studios may redact from the data which it will make available to you, any personal information related to others.


10. Your EU Data Subject Rights

ayeT-Studios is committed to assist its controllers as to data subjects’ rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).

Please note that under the GDPR ayeT-Studios processes data provided into the Services as a processor and not as a controller (i.e. Supply Partners). As a processor, ayeT-Studios is committed to assist its controllers to fulfill data subjects’ GDPR rights.

Therefore, if you wish to exercise your rights under the GDPR or have any questions in this matter, please contact the relevant ayeT-Studios’ controller directly. When needed and upon request, ayeT-Studios will assist its controllers.

ayeT-Studios conducts periodical assessments of its data processing and privacy practices to ensure that it complies with this Policy, update the Policy when necessary, and ensure that the policy is properly displayed and accessible.


11. Data Retention

As a general practice, ayeT-Studios stores your personal information for as long as you use the Property and for a 30 days thereafter. ayeT-Studios uses your personal information in these cases for internal reporting, analysis and to provide the Services. ayeT-Studios may save and use your personal information, in certain required cases, for a longer period of up to 90 days after you discontinue using the Property, if ayeT-Studios needs your personal information for invoicing, reporting, discrepancy investigation reasons.

ayeT-Studios also uses and stores your personal information to prevent fraud. In certain cases, where ayeT-Studios suspects that the Property that you have used may be vulnerable to fraudulent activities, ayeT-Studios may store and use your personal information, if needed, after you discontinue using the Property for fraud detection purpose.

Please note that ayeT-Studios may be required to retain certain information by law. Aggregated data may be retained by ayeT-Studios for longer periods and via a third-party analytics platform.

ayeT-Studios will ensure that personal information processed for no longer than necessary for the purposes for which the personal information was provided.

In any case, as long as ayeT-Studios uses your personal information to provide the Service, ayeT-Studios will keep the information about you, unless ayeT-Studios is required by law to delete it, or if ayeT-Studios accepts your request to delete the information, pursuant to applicable laws, or if ayeT-Studios decides to remove it at its discretion.

As a Customer, as long as you use the Services, ayeT-Studios will keep information about you, unless it is required by law to delete it, or if ayeT-Studios decides to remove it at its discretion.


12. Transfer of data outside your territory

ayeT-Studios may store and process information in various sites throughout the globe, including in sites operated and maintained by cloud-based service providers.

If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide ayeT-Studios your express and unambiguous consent to such transfer.

If you are a resident of the European Economic Area (EEA), your personal data is processed and stored by Amazon Web Services (AWS) Cloud in the US on ayeT-Studios’ behalf in accordance with the highest degree of security of AWS.

ayeT-Studios may implement additional onward transfer mechanisms, as may be available from time to time.


13. Information Security

ayeT-Studios is committed to safeguarding the confidentiality of your personal information. ayeT-Studios and its hosting services implement systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

As an example, ayeT-Studios limits access to information to authorized personal on a need to know basis in order to operate, develop or improve the Services.

While all measures provided reflect the current industry standard of security, ayeT-Studios cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.


14. Changes to this Privacy Policy

From time to time, ayeT-Studios may update this Policy. If the updates have minor if any consequences, they will take effect 7 days after ayeT-Studios posts a notice on the Services’ website. Substantial changes will be effective 30 days after ayeT-Studios’ notice was initially posted.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Services. Continuing using the Services after the new policy takes effect means that you agree to the new policy.

Note that if ayeT-Studios needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.


15. Contact Us

Please contact ayeT-Studios’s Data Protection Officer at: privacy@ayetstudios.com for further information.


Last updated: May 24, 2018

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