Privacy Policy:

Last Revised: 24 May 2018

Avows considers it essential to comply with our customers, the provisions of the General Data Protection Regulation (GDPR) and the respective national data protection laws.

Controller Contact Information
The Controller within the meaning of the Art 4 (7) GDPR and other national data protection laws of the Member States and, at the same time, the service provider within the meaning of the Telemedia Act (TMG) is:

Avow GmbH

Am Treptower Park 21

12435, Berlin

AVOW GmbH (“Avow”, “we”, “our” or “Company”) welcome you, a visitor of https://www.avow.tech/ (“website” or “site”) and third party advertisers (“Advertiser”) and third-party publishers (“Publisher”) using our service as detailed below.

Avow is an online platform enabling our Advertisers to display advertisements and marketing materials to end users who use or otherwise interact with certain mobile webpages and desktop websites (“Digital Asset”) owned by our Publishers (collectively, the “Service”).

For the purposes of this privacy policy (“Privacy Policy”) a “User” shall refer to a visitor of the site, an Advertiser or Publishers as well as their applicable end users.

Capitalized terms which are not defined herein, shall have the meaning defined to them in our Terms and Conditions available at the following sites. This Privacy Policy is incorporated by reference (collectively, the “Terms”).

https://www.avow.tech/advertiser-terms-and-conditions/

https://www.avow.tech/terms-conditions/

We have included below information about which data is collected, how we process and use your data, but before we would like to explain the basis on which we do so:

1. Where you sign up for any of our Services, we process your personal data in order to perform our contract with you;

2. If we have a legitimate interest in processing data, such as for direct marketing, online advertising or online identifiers when you access our Site or use our Services; or

3. We will also process your personal data where you have provided us with consent to do so.


INFORMATION WE MAY COLLECT

We may collect two types of data and information from our Users. The first type of information is non-identifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from which we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while Users are using the Services. Non-Personal Information which is being gathered consists of technical information and behavioural information, and may contain, among other things, the activity of the User on the Services, type of operating system and type of browser, type of device, User’s connection to the Site, or approximate geo-location.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes either: (i) contact information such as your name, email address, etc., which you have submitted voluntarily; or (ii) your Internet Protocol (“IP”) addresses (the addresses of computers on the Internet), advertising ID, IDFA (collectively, “Identifier”). Note that, while Identifiers are considered Personal Information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data is not considered as Personal Information. Therefore, we treat such information as Personal Information, in accordance with applicable laws, however we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any Personal Information such as your name or email address. The IP may be collected by our third party analytic partners that offer ways to opt-out, all as detailed below.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

You are not required by law to provide us with any information. You can always avoid from providing us certain Personal Information; however, you acknowledge that it may prevent you from engaging in certain Services.

 

Information we collect from visitors of the Avow Website and Users of our Service

Type of Information -

In the event you ontact us for support or other inquiries, either through the nline form available on our website, by sending us an email or by other means of communications we make available, you will be requested to provide us your name and email address.

How we use that information -

We will use this information solely for the purpose of responding to your inquiries and provide you with the support or information you have requested.

Type of Information -

In the event you are interested in joining our team, and wish to submit your C, you will be required to provide us your name, email address, and CV.

How we use that information -

Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide us.  We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use  the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you  are hired, the information may be used in connection with employment and corporate management.

Type of Information -

Identifiers

How we use that information -

We either directly or indirectly may collect our visitors of the Site IP or Identifiers when using the Services. We use  this for our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Site and Services and the way in which we offer them; (ii) enhancing your experience  with the Services; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow; and (iv) our legitimate interest of serving personalized advertisements on Digital Assets.

Type of Information -

We also collect certain echnical Non-Personal Information (as detailed above) which relates to your use of the Services or the Website.

How we use that information -

We use this technical information to operate and manage our website.



Information We Collect from Advertisers or Publishers

Type of Information -

In order to use our Services as an Advertiser or Publisher you will be required to enter into a physical agreement with Avow GmbH.

How we use that information -

We will use this information for the purpose of performing our contract with you in order to provide you with the services you have authorized.

Type of Information -

We also collect certain echnical Non-Personal Information (as detailed above) as a visitor to the site and as detailed above.

How we use that information -

See the table above


HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the Services, we may collect information as follows:

1. Automatically – we may use Cookies (as elaborated in the section below) to gather some information automatically.

2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a physical agreement, contact us communications, etc. all as detailed in this Privacy Policy.

 

SHARING INFORMATION WITH THIRD PARTIES

Avow will not share any Personal Information it collects with any third party. Notwithstanding, Avow may disclose Personal Information in the following cases: (i) ompelled Disclosures. o satisfy any applicable law, regulation, legal process, subpoena or governmental request; (ii) nforcement of our Rights. To enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (iii) raud Detection. To detect, prevent, or otherwise address fraud, security or technical issues; (iv) usiness Transfer. When Avow is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (v) ervice Providers. To collect, hold and/or manage your Personal Information through Avow’s authorized third party service providers, as reasonable for business purposes; (vi) xplicit Consent. Pursuant to your explicit approval prior to the disclosure; or (v) dentifiers. We may share identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Services, as well as talculate payments in connection with the Services.

For avoidance of doubt, Avow may transfer and disclose or otherwise use Non-Personal Information or information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable way, at its own discretion.


DATA DELETION AND STORAGE

The personal data of the affected person are generally deleted or disabled as soon as the purpose of storage expires.

Furthermore, storage may also occur if so required by European or national law under European Union regulations, laws or other provisions to which the Responsible Body is subject.

Blocking or deletion of data is carried out even if a storage period specified by the standards referred to expires, unless there is a need for further storage of the data in order to conclude or execute a contract.

 

DELETION OR MODIFICATION OF PERSONAL INFORMATION

Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Information. ubject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Information to another party.

The principal rights under applicable data protection law in relation to Personal Information are as follows:

  • the right to access any information which is provided to us;

  • the right to rectification;

  • the right to erasure;

  • the right to restrict processing;

  • the right to object to processing;

  • the right to data portability;

  • the right to complain to a supervisory authority; and

  • the right to withdraw consent (to the extent applicable).

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information, depending on your relationship with us. If you wish to exercise any or all of the above rights, please contact our Data Protection Officer at: ataprotection@avow.tech and let us know that you wish to exercise your right of access and specify what Personal Information you would like to receive. Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

 

THIRD PARTY SOFTWARE/SERVICE

While using the Avow Services we may be using third party software and/or service for various needs, inter alia, in order to collect and/or process the information detailed herein (“hird Party Service Provide”).

Note that these are independent software and/or service providers and Avow does not take any liability about the information collection policies of these providers relating thereto. Currently, our Third Party Service Providers are the following (we will update this section from time to time if we add or remove Third Party Service Providers:

 

USE OF COOKIES

When you access or use our Site, the Avow may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your service experience much more convenient and effortless. The cookies used by the Site are created per session, which does not include any information about you, other than your session key and are removed as your session ends. It is easy to prohibit the Local Storage. Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited.

In this regard, following are some links which you may find useful:

Browser Opt-out:

Mobile Opt-out:

 

Self-Regulation Opt-out:

You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services such as (1) the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or (2) the Digital Advertising Alliance’s (“DDA”) website – DAA opt-out page or (3) If you wish to opt out of interest-based advertising, you may click here. Please note you will continue to receive generic non targeted ads.

In the event, that you have any additional complaints about your privacy rights, please initially contact the Data Protection Officer at: ataprotection@avow.tech and we will be happy to assist you. Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer. Please note that you have the right at any time to contact your local data protection authority.

 

SECURITY

We take great care in implementing and maintaining the security of Company’s Website, Avow Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information and prevent unauthorized use of any such. We have implemented technical, physical and administrative security measures to protect the Personal Information, including without limitation by using industry standard encryption (SSL). In addition, we limit access to your information on our servers. The data collected by us is stored in the AWS data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse Company’s Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

 

PROTECTING CHILDREN

The Avow Services are not directed to children and we do not knowingly collect information from children. If you have any information regarding a use of a minor under the age of eighteen (18) please let us know at: dataprotection@avow.tech. You must be at least eighteen (18) years of age to be an Avow client and access our services. By agreeing to these Terms, you represent and warrant to us: (i) that you are at least eighteen (18) years of age; (ii) that you have not previously been suspended or removed from Avow’s network; and (iii) that your registration and your use of the Avow services is in compliance with any and all applicable laws and regulations.

 

CHANGES TO THE PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the Avow GmbH Services and any information collected therein. Avow reserves the right to change this policy at any time, so please visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the Site. Such substantial changes will take effect seven (7) days after such notice was provided on the Avow website or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of Avow Services after the last update date will constitute acceptance of, and agreement to be bound by, those changes.

 

DATA TRANSFER

We may store or process your Personal Information in the Germany or in other countries. If you visit our website or use our Services from locations outside of the Germany, please note that any information you provide to us through your use of our Websites or Service may be transferred to and processed in countries other than the country from which you accessed our Websites or Service, including Germany where our central database is operated. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

 

DO NOT TRACK DISCLOSURE

The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

 

ADDITIONAL INFORMATION AND CONTACT US

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: dataprotection@avow.tech or mail us at: Avow GmbH, Am Treptower Park 21, 12435, Berlin, Germany and we will make an effort to reply within a reasonable timeframe.

By contacting Avow you warrant and agree that you are free to do so, and that you do not provide Avow with information, which violate any third party intellectual rights (“Information”). Without degrading from the aforesaid, all rights, including intellectual property, arising from the communication will be owned by Avow and will be considered as Avow’s confidential material. It is clarified that any use of the Information, will be done in Avow’s sole discretion, and Avow is not obligated to use all or part of this information.

 

DATA PROTECTION OFFICER

  • If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dataprotection@avow.tec.Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.

  • The right to revoke your consent;

  • The right to object to the processing;

  • The right to data portability;

 You can assert all of these rights by contacting our Data Protection Officer at contact@avow.tech