Privacy Policy

1. Introduction

Definitions

MediaCruiser shall mean:

Global and Beyond Technologies Limited, having its registered office 3rd Floor, Atlantic House, 4-8 Circular Road, Douglas, Isle of Man, IM1 1AG, Isle of Man, incorporated under the laws of the Isle of Man with registration number 018198V and VAT number GB005395392 (hereinafter also referred to as “MediaCruiser, We, Us”)

Our Platform shall mean:

MediaCruiser Platform available at: www.mediacruiser.com (“the Site”)
We can be contacted by writing to:
[email protected]

Customer (“hereinafter also referred to as “You”, “Your”) shall mean:
- the company or legal entity accepting this Agreement and in the event of an individual accepting this Agreement on behalf of a company or other legal entity, then such company or other legal entity; or (ii) in the event of an individual accepting this Agreement and/or executing an Order Form on his or her own behalf, then such individual.

Services shall mean:
selling of the Digital Traffic for advertising purposes, as defined in our Terms and Conditions.

Credit shall mean:

the provision of financial resources by one party (the “Lender” or “Creditor”) to another party (the “Borrower” or “Debtor”) with the expectation of future repayment. This financial arrangement involves a line of credit, where the Borrower is granted access to funds, and repayment is made according to the agreed-upon terms, which may include interest, fees, and a specified repayment schedule. The extension of credit is contingent upon the lender’s assessment of the borrower’s ability to repay the borrowed funds.

Data Protection Laws shall mean:

The legal frameworks, regulations, and statutes that govern the collection, use, storage, and processing of personal data. These laws are designed to protect individuals\’ privacy rights and ensure that personal data is handled in a secure and transparent manner. They impose obligations on organizations that process personal data to ensure the data is managed responsibly and in compliance with specific principles, such as fairness, transparency, data minimization, and security.
Data protection laws include, but are not limited to, the General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”)), the Data Protection Act 2018 in the United Kingdom (“UK GDPR”), California Consumer Privacy Act (“CCPA”) as well as Children’s Online Privacy Protection Act (“COPPA”) and other applicable national or regional laws that provide protections for personal data.

This Privacy Notice (“Notice”) describes how Your personal information is collected, used, and shared when You visit our platform available at https://www.mediacruiser.com, purchase MediaCruiser Services on the Site, as defined in our Terms and Conditions, or otherwise interact with the Site.

2. Your Data Collected by Us
As you engage with our Platforms, we gather data concerning a recognized or identifiable living individual (\”personal data\”) through the following means:

Data Directly Provided by You: this encompasses any information you manually input or furnish to us while utilizing our Platforms. For instance, this might include details like your name, email address, phone number, photo, geolocation data, place names and addresses, added by you or any other information you decide to disclose during registration or account setup.
Data Automatically Collected by Us: when you access Our Platform, We automatically procure certain details regarding your engagement and activities within the Platform. This may entail specifics about your device, such as its model, operating system, unique identifiers, IP address, and data related to your actions within Our Platform.
Data Acquired via Cookies: to understand your interactions with our Platforms better, we utilize cookies and similar technologies. Cookies enable us to retain particular details about you, such as your preferences or previous interactions, thereby enhancing your experience on our Platforms and delivering tailored content. You can find more in our Cookie Policy.

3. Customers

a. Customer Information We collect

We collect Customer Information directly from our Customers in the following ways:

Site:
- We will collect a Customer’s contact details when a Customer enters a contractual relationship with MediaCruiser and we will collect a username and password when a Customer creates an account on Our Platform.
- When a Customer sends us an email asking a question, or signs up to receive our email newsletters, we will collect the Information that the Customer submits to Us.
- We will also collect other Information that Customers choose to provide to Us, such as the contents of a message or form that a Customer submits through our Platform or via email.
- We may also collect Information from prospective customers through publicly-available sources.
Services:
- When a Customer signs up to use our Services, we collect Information such as the Customer’s name, email address, telephone number, billing information, and any other Information the Customer may choose to provide to us on the platform.
- We may also work with third party vendors to process payments to or from our Customers on our behalf. These vendors currently include Stripe Inc, but are subject to change at any time. We do not have access to the Information that You provide to these third parties, and we encourage You to visit their privacy policies to understand their practices.

b. Why we collect Information

We use Customer Information for the following purposes:

Providing our Services. We use Customer Information to provide our Site and Services and for other customer service purposes in relation to Customer accounts.
Communicating with You about Your MediaCruiser Partnership. We use Customer Information to communicate, via email or otherwise, about Customers’ accounts; to contact Customers about MediaCruiser’s products or services that we think may interest You; to respond to Customer inquiries, requests, or complaints; and to provide Customers with product updates, news, best practices, and other helpful or interesting information that can enhance Your use of MediaCruiser’s Services, in accordance with their communications preferences. When we communicate in this way, our emails may deploy a cookie that tracks when the emails are opened to measure Customer engagement. For more information about cookies, please see our Cookie Policy.
Marketing and advertising. We use Customer Information to provide Customers with newsletters, special offers, and promotions, including via email; and for other marketing, advertising, and promotional purposes, including general updates about MediaCruiser. These communications will be sent in accordance with our Customers’ communications preferences.

c. To whom we disclose Customer information

We may disclose Customer Information as follows:

MediaCruiser’s Affiliate. We may disclose Customer Information to any of MediaCruiser’s current or future affiliates (affiliates are companies controlling, controlled by, or under common control with us referred to herein as “Affiliates”), parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.
MediaCruiser service providers. We may disclose Customer Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf.
Customers. We may disclose Customer Information to other Customers where relevant to the Service we provide.

4. User Information

a. User Information we collect

On our MediaCruiser Platform: User’s device and operating system, IP address,, the dates and times a User accesses a MediaCruiser platform, event information (e.g., system crashes), general location information (e.g., city and state). Information made available by the User – name, surname, company name, company address, company SSN/TAX/Vat number, phone number, email.

b. To whom we disclose User Information

MediaCruiser’s Affiliate. We may disclose Customer Information to any of MediaCruiser’s current or future affiliates (affiliates are companies controlling, controlled by, or under common control with us referred to herein as “Affiliates”), parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.
MediaCruiser service providers. We may disclose Customer Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf.
Unaffiliated third parties. We may disclose User Information to other unaffiliated third parties, specifically with (i) our data partners, so that we can connect you with relevant content by allowing our advertisers to target specific audience segments, and (ii) our programmatic demand and supply partners, so that we can serve you with tailored advertisements.
Customers. We may disclose Customer Information to other Customers where relevant to the Service we provide.

5. Legal Basis of Processing

a. Types of Legal Basis we use description

Legitimate interest: We process Your usage data on this legal basis to technically improve the Platform based on Our legitimate interests of fraud prevention, security enhancement, and service optimization, and after conducting a comprehensive balancing test that confirms our interests do not override the fundamental rights and freedoms of data subjects.
Contract: We process Your usage data on this legal basis to fulfil the contractual duty of granting You access to use Our Platform.
• Legal obligation: We process Your usage data on this legal basis to comply with pertinent laws and regulations. This implies that We may handle personal data as mandated by law, ensuring adherence to applicable legal mandates.
Consent: We process your usage data on this legal basis to promote Platforms and optimize our advertising efforts to effectively tell more people about Platforms. We are committed to being clear and transparent so that You can really understand what We do with Your data. Below, We explain the purposes for which We process Your personal data and the legal basis supporting this.

b. Legal Basis Purpose of Processing Example

We will not process Personal Data unless there is a legal basis for such processing. The following outlines the purposes for which we may process your Personal Data and the legal basis for any such processing:

Purpose	Legal Basis
To provide and enable use of the Services	Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
To contact you regarding operational updates	Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
To respond to queries, requests, or complaints, and to provide support services	Processing is necessary for the purpose of legitimate interests pursued by us or by a third party (including our Partners).
To provide tailored Services, advertising, and marketing materials	We may process Personal Data about you to offer additional services, products, and features. This includes using automated techniques such as profiling to adjust the content according to your preferences, behaviors, and interests.
To improve our Services and offer new ones. We may process Personal Data to improve our Services, analyze previous uses, and address issues or errors.	Processing is based on your consent and is necessary for the purpose of legitimate interests pursued by us or by a third party (including our Partners).
To send you advertising and marketing materials	With your consent, we may send advertising and marketing materials relating to our Services, existing or new, as well as products or services of third parties (including our Partners). It is clarified that if you withdraw your consent, it may not necessarily cause the deletion of your details held by third parties (including our Partners).
To analyze the effectiveness of marketing and advertising campaigns	Processing is necessary for the purpose of legitimate interests pursued by us or by a third party (including our Partners).
To perform and maintain various activities supporting the provision of our Services Such activities include back-office functions, business development, technical functionality, security measures, and strategic decision-making.	Processing is necessary for the purpose of legitimate interests pursued by us or by a third party (including our Partners).
To perform analysis, including statistical analysis We may use analytical measures, including statistical analysis, to improve existing services and introduce new products and services.	Processing is necessary for the purpose of legitimate interests pursued by us.
To protect our and third parties\’ (including our Partners) interests, rights, and assets, including initiation, exercise, or defense of legal claims.	Processing is necessary for the purpose of legitimate interests pursued by us or by a third party (including our Partners).

Legitimate interest: Responding to Your requests. We may process Your name and email, e.g., to properly respond to Your request.
Contract: Processing transactions and sending you related information, including confirmations, receipts, platform notifications and reminders for account management and other administrative purposes. We may send you reminders regarding payments, or we may email you containing your invoice, if applicable, using your device data.
Consent: Making offerings to You. We may offer You some Credit.

c. Data Retention

We retain Your personal data for as long as necessary for our legitimate business purposes, including resolving disputes, ensuring safety and security, and complying with legal obligations. We may retain personal data for up to twenty-four (24) months from the date of account deletion, after which we will de-identify or aggregate the data to protect individual privacy.

6. Data Subject Rights

Please note that if You are an EEA resident, the General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”)) applies to the processing of Your personal data. We adhere to the GDPR.
We also apply substantially the same standards of data protection to all of our users taking into account (if any) limitations, exemptions, or privileges imposed by Your national law.

According to the applicable data protection legislation, You may have the following data protection rights:

a. right to access:

You are able to request access to Your personal data that we store about You. Among others, You may ask Us regarding:

the purposes for collecting personal information about You;
categories of personal information concerned;
who receives Your personal information or categories of such recipients;
how long We are going to store the information about You and if not possible criteria to determine the storage period;
when Your personal information was obtained not from You directly, the source where it came from;
the existence of either profiling activities or automated decision making based on Your personal information. Where such activities are performed, We should also inform You about the importance, and expected consequences of them;
a copy of Your personal information processing. For such requests further, We may charge You with a reasonable fee. We generally provide users with an electronic copy of their personal information unless they request otherwise.

b. right to rectification:

You have the right to correct inaccurate (for example, old or incorrect) personal information related to You.

c. right to erasure or the right to be forgotten:

You have, under certain circumstances, the right to request the erasure of Your personal information. Please note, that this right only applies to the data available at the time of request and is not applicable to future data.
Request to the erasure of personal information is possible when:

personal information is no longer needed for the purposes it was primarily collected or processed;
when You have already withdrawn your consent for processing Your personal data, and We do not have other legal ground to process it;
when Your personal data is processed under legitimate interest and You object to such legal ground. Moreover, there is no overriding legitimate interest to proceed with processing of Your personal data;
Your personal information was unlawfully processed;
when Your personal data has to be erased due to legal obligation.

d. right to restrict processing:

You may request Us to stop processing Your personal information when:

You have reasonable doubts that Your information is accurate, and We are verifying the accuracy of such information;
Your personal information was unlawfully processed;
The purpose of Your personal information collection no longer exists, but You wish to store it longer to defend a legal claim.

Moreover, You may request Us to stop processing Your personal data while We are working on a rectification request or request to object to the processing of Your personal information.

e. right to data portability:

You have the right to obtain from us and further reuse Your personal data for Your own purposes within other services. You will also be able to transfer Your personal information from one IT environment to another in a safe and secure way, when certain conditions apply, such as:

the processing is based on Your consent or needed for the performance of a contract with You;
the processing is made only electronically, without any paper-based files included.

f. right to object:

You have the right to object to the processing of Your personal information at any time by contacting us at [email protected]. This allows You to prevent Us from (stop) processing Your personal information. This right applies only when one of the following conditions are met:

Your personal information is used for direct marketing purposes;
the processing is based on Our legitimate interest;
We are performing tasks carried out for the public interest or by governmental authority;
Your personal information was processed for either research or statistical purposes.

g. right not to be subject to automated decision making and profiling:

Neither We nor the Platform uses Your personal data for profiling or decisions made solely by automated means.

h. right to lodge a complaint with a supervisory authority:

You have a right to lodge a complaint with a data protection authority in a country You either reside, permanently live, work, or in a country where data protection infringement takes place. Please let Us know if You have any concerns as to Your personal data or Our processing of it at [email protected]. We will do our best to respond to You as quickly as possible given the number of requests we receive at the time You contact us. In any case, we strive to respond to every complaint we receive within one month; however, for EU-U.S. (UK-U.S., Swiss-U.S.) DPF the response time shall not exceed 45 days as required under the DPF Principles.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, MGID commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If You do not receive timely acknowledgment of Your DPF Principles-related complaint from us, or if We have not addressed Your DPF Principles-related complaint to Your satisfaction, please visit https://www.jamsadr.com/ﬁle-a-dpf-claim for more information or to ﬁle a complaint. The services of JAMS are provided at no cost to You.

If Your DPF complaint cannot be resolved through the above channels, under certain conditions, You may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

Please note: as required by national laws, We may be legally compelled to disclose Your data after receiving a court order, a subpoena or any other official request of a competent public authority (for example, we are subject to the investigatory and enforcement powers of the FTC or any other U.S. authorized statutory body, the EU data protection authorities, the police, etc.), including to meet national security or law enforcement requirements.

You may access, correct, or update the personal data that You have provided to Us by either updating the personal data in Your account, by emailing Your personal account manager, or by emailing Us at [email protected].

We may send periodic promotional or informational emails to You. You may unsubscribe from receiving them (opt-out of such communications) by following the opt-out instructions contained in the email (such as clicking the “unsubscribe” link in the footer of the email).

7. Children’s Privacy

Protecting children’s privacy is very important to Us. Our Platform is not intended for, designed to be used by, or targeted at children as defined in Applicable law.
We are in compliance with the requirements of GDPR, California Consumer Privacy Act as well as Children’s Online Privacy Protection Act (“COPPA”) and we do not knowingly collect any personal data from anyone under 16 years old.
In the event that we learn that we have inadvertently gathered personal data from anyone under 16 years old, we will take reasonable measures to promptly erase such information from our records.
If you are a parent and learn that your child is using our Platforms without your permission, or if you have a specific question about data privacy, do not hesitate to get in touch with us via [email protected].
If we become aware that information has been collected from persons under the age of 16, we reserve the right to promptly delete the account and erase all associated information, including health and sensitive data, from our servers.

8. Security Measures

We use a Role-Based Access Control (“RBAC”) as a security model to restrict access to Your personal data. RBAC refers to a system of managing access to personal data and information based on the roles assigned to individuals within an organization. Under RBAC, access to sensitive or confidential data is granted based on the user\’s role, job responsibilities, and the principle of least privilege, ensuring that individuals only have access to the data necessary for their functions. RBAC is implemented to safeguard personal data by restricting access and reducing the risk of unauthorized use, disclosure, or alteration of personal information.

9. Data Breach notification

In the event of a personal data breach, We take the security of Your data seriously and are committed to protecting Your personal information. We will notify You without undue delay, and in any case within 72 hours of becoming aware of a breach that may affect Your personal data and poses a risk to Your rights and freedoms.

a. Notification to Affected Users

If a data breach occurs that affects Your personal information and is likely to result in a high risk to Your rights and freedoms, We will inform you directly via email or other means of communication as soon as possible. The notification will include the following information:

A description of the nature of the breach, including the categories and approximate number of affected data subjects and records;
The likely consequences of the breach;
The measures we have taken or propose to take to address the breach, including any steps You can take to mitigate potential negative effects (if applicable);
Our contact details for further inquiries.

b. Notification to Regulators

In compliance with applicable Data Protection Laws, We will also report the breach to the relevant supervisory authority in the jurisdiction in which the breach occurred. This notification will be made within seventy-two (72) hours of Us becoming aware of the breach, unless the breach is unlikely to result in a risk to Your rights and freedoms.

c. Mitigation and Prevention

In the event of a breach, We will take immediate corrective action to mitigate any harm and prevent similar incidents from occurring in the future. This includes, but is not limited to, reviewing Our data security protocols, implementing additional safeguards, and enhancing staff training.

d. How You Can Help Protect Your Data

We encourage You to take immediate action to protect Your personal data in the event of a breach. This includes reviewing Your accounts for any suspicious activity and changing passwords or other sensitive information that may have been compromised.
If You have any questions about Our data breach procedures or if You believe Your data has been affected by a breach, please contact Us immediately at [email protected].

10. Update to this Privacy Policy

We may update this Privacy Policy occasionally to align with legal changes, modifications in our data collection and usage practices, updates to our Platforms, or advancements in technology. We encourage you to review this page periodically to stay informed about any updates, and refer to the “last updated” date at the top of the page to see when it was last revised. If we make significant changes to this Privacy Policy that affect your consent, we will inform you accordingly.