Privacy Policy

Last modified: May 25, 2018

We have recently updated our Privacy Policy to comply with the new requirements set out by the EU General Data Protection Regulation and to make it easier to read. The updated Privacy Policy shall be deemed effective as of May 25, 2018. Your continued use of our site be subject to our new Privacy Policy.

Welcome to our Privacy Policy!

When you visit our site and/or deal with our technologies and services, whether you are a client (i.e. an Advertiser or a Publisher) or an end-user (i.e. a visitor of our site or a visitor/customer of our clients’ sites), you will share and/or we will collect/access some personal information about you. Please be assured that we are fully dedicated to the protection of your personal information.

Because your privacy is so important to us, we provide you with this Privacy Policy, explaining how we collect, use and share your personal information, so that you can make informed choices about the use of your data.

Please read this Privacy Policy carefully. We have tried to write it in a way, which is free of long boring sentences and legal terms. You can contact us if you have any question about our privacy practices or about what we are doing with your personal information. We will be happy to provide you any assistance you may need.

1. WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The company which decides how and why your personal data is processed, and which is called “Data Controller” is:

Duodecad IT Services Luxembourg S.à r.l., a private limited liability company (“société à responsabilité limitée”) organized and existing under the laws of Luxembourg, registered in the Luxembourg Trade and Companies register under number B171.358, having its registered office at 44 Avenue John F. Kennedy, 1855 Luxembourg, Grand Duchy of Luxembourg.

If you are an end-user of one of our clients’ websites, the information that we process about you is jointly controlled with our clients, the Publisher and the Advertiser.

2. WHAT PERSONAL DATA DO WE PROCESS?

2.1. You are a visitor of www.awenetwork.com

  • Log data and device information

    When you visit our site, we temporarily store log data and information from or about your computer, phone, or other device you use to access or navigate on our site. This includes:

    • your IP address;
    • the date, time and duration of your visit;
    • the hardware, software or internet browser you use;
    • information about your computer’s operating system, like application version;
    • identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
    • the website you were referred from to our website, that is say the referrer URL;
    • the type of device you are using.
  • Information collected by cookies and other technologies

    • Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device.
    • Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may affect your use of our site. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

2.2. You are an Advertiser or a Publisher

2.2.1. Personal information we get when you register on our site or contract with us in any other way

When you register on our site or contract with us in any other way, we will need to collect the following personal information about you:

  • Your identification details: your first name, last name, username;
  • Your contact information: your email address, your address, city, zip code, and country and/or, as the case may be, your skype username, your ICQ number;
  • If you register as a company, your company name, company registration number, VAT number.

2.2.2. Personal information we get when you contact the AWE Network Support or communicate with us

We collect all information you choose to share with the AWE Network Support, like your personal e-mail, your feedback, comment or request and your conversations with Support.

More generally, when you communicate with us in any other way, we will collect the information you provide us.

2.2.3. Personal Information we get when you are browsing on the Advertiser or Publisher interface

  • Log data and device information

    When you visit our site, we temporarily store log data and information from or about your computer, phone, or other device you use to browse on the Advertiser or Publisher interface. This includes:

    • your IP address;
    • the date, time and duration of your visit;
    • the hardware, software or internet browser you use;
    • information about your computer’s operating system, like application version;
    • identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
    • the website you were referred from to our website, that is say the referrer URL;
    • the type of device you are using.
  • Information collected by cookies and other technologies

    Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device.

    Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may affect your use of the services on our site. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

2.2.4. Transaction information

We process the information you provide us with for payout or payment and invoicing purposes, depending on whether you are an Advertiser or a Publisher.

If you choose to execute the transaction through a virtual account (if available), we will not be responsible for the data you provide to this third party to create and manage your virtual account. Please check directly the privacy policy of the virtual account provider if you want to learn more.

2.3. You are an end-user of one of our client’s website and interact with our technologies and services

  • Usage Information

    We are processing some information about you, if you are an end-user of one of our clients’ websites when you interact with the ads. The information collected includes:

    • the type of advertisement you interacted with;
    • which advertisement you interacted with;
    • the financial data associated with the advertisement (precisely, how much the Advertiser paid for it and how much revenues it brought for the Publisher);
    • the tracking pixel in the advertisement (if any).
  • Log data and device information

    When you visit our clients’ websites, they temporarily store log data and information from or about your computer, phone, or other device you use to access or navigate on their websites, and they transfer further such data and information to us. This includes:

    • your IP address;
    • your location (city, country);
    • the date, time and duration of your visit on our clients’ websites;
    • the hardware, software or internet browser you use;
    • information about your computer’s operating system, like application version;
    • identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
    • the publisher site where the advertisement was displayed;
    • the type of device you are using.
  • Information collected by cookies and other technologies

    We use cookies to provide our tracking services. Cookies are small text files that are placed on your device (e.g. your computer, phone or tablet) when visiting and navigating on certain websites and applications. Cookies may track certain of your activities or preferences. Internet cookies are common and will not cause any harm to your device.

    Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may affect your use of the features of the site on which you navigating.

    The only purpose of our tracking cookies is to measure the effectiveness of the advertisement and to allocate the successful advertisement to a particular business transaction in order to be able to execute the billing services

3. WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect for the following purposes:

3.1. You are a visitor of www.awenetwork.com

We collect and process log data and your device information in order to facilitate the use of our site, to ensure the security of our systems and the technical administration of the network infrastructure.

We process this information given our legitimate interest in ensuring the smooth running of our site, as well as, information, system, and network security.

3.2. You are an Advertiser or a Publisher

3.2.1. Open your Advertiser or Publisher account and/or register you as a Publisher/Advertiser in our system

We use the personal data you give us to create and administer your online account and/or register you as an Advertiser or Publisher in our systems.

We process this information as it is necessary for the adequate performance of the contract we have with you.

3.2.2. Display your dashboard as regards your marketing activities

  • We use and analyze your data to display a dashboard with information, including statistics, about your activity as an Advertiser or Publisher.
  • Please note that this information is only showed to you in your account and help you to have visibility on your activity and the payout/payments made.

We process this information given our legitimate interest in providing a good user’s experience and a perfect visibility over your activity.

3.2.3. Customer relationship management and communication with you

  • Sharing your personal details with our Support team allows us to respond to any question you might have. When receiving a request or claim from you, our Support Team can access all information you give to us and all information we collected about you. We want to make sure that our Support team has all information needed to appropriately and immediately respond to your request.
  • Please note that we may also communicate with you through emails or any other means, if appropriate, in order to inform you of certain changes regarding our site or of certain events/actions, for example, when you successfully register on our site.

We process this information given our legitimate interest in improving our users’ experience and delivering appropriate customer services.

3.2.4. Payment and Accounting

  • We use your data for payment/payout and accounting purposes to process transactions and maintain legally required business records.

We process this information, as it is necessary for the adequate performance of the contract we have with you once you register as an Advertiser or Publisher.

3.2.5. Ensure a safe and trustworthy environment

  • Because we want to create and ensure a safe environment, we use your personal data to detect and prevent fraud and other illegal activities related to the use of our site.
  • We use your personal information for security purposes and risk assessment, such as to authenticate you on our site and verify your identity.

We process this information given our legitimate interest in ensuring fraud detection and prevention, as well as, information, system, network and cyber security.

3.2.6. Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data, such as for accounting purposes, to respond to requests of competent authorities or to establish, exercise or defend legal claims.

3.3. You are an end-user of one of our client’s website and interact with our technologies and services

The only purpose of the processing of you data (as listed above) is to measure the effectiveness of the advertisement and to allocate the successful advertisement to a particular business transaction in order to be able to execute the billing services.

We process this information given our legitimate interest in providing ad-tracking services to Advertisers and Publishers and make you ad interaction efficient.

4. HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement serious security measures to grant maximum protection to your personal information against unauthorized access, modification, disclosure or deletion. Your data is always protected by our highly sophisticated security systems.

We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our site and the entire IT infrastructure related to it are updated against the latest network security vulnerabilities. We periodically test our IT systems and do sophisticated penetration tests. Our site incorporates the most advanced security technologies available in order to ensure maximum safety of its users and the safekeeping of their information.

5. WITH WHOM DO WE SHARE YOUR DATA?

We share your data with the following parties:

5.1. Entities of our company’s group and our external account managers

We share your personal information with the following companies of our group based in Luxembourg and Hungary, as they are helping us to deliver the ad network related services:

  • Docler Holding S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
  • External account managers located in Spain.

5.2. Payment providers and financial institutions

If you are an Advertiser or a Publisher, in order to process your payment/execute the payout, you may share certain information with a third party bank or payment processor.

You may receive transactional emails from this party confirming the receipt of your referral fees, including other possible relevant notifications.

If you share information with third parties directly, this Privacy Policy does not govern that information.

We may furthermore share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.

5.3. Law enforcement agencies or governmental authorities

We may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our Terms of Service, and/or (d) protect our rights or defend ourselves against any claims.

5.4. Business transfers

Finally, please also note that your information may also be transferred to another company in the event of sale of the whole or part of our business to a third party.

5.5. Advertisers / Publishers

If you are an end-user of one of clients’ websites (Publishers) and interact with the ads, some of the information collected about you may be shared with the Advertisers or Publishers, as your information is jointly controlled with our clients.

6. HOW DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA?

As we are a Luxembourg based company, we comply with the EU Data Protection Regulation commonly called “GDPR” (If you want to learn more you can check: EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC), which provides a high level of protection of your personal data.

In case we need transfer your personal data outside of the European Economic Area, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we will utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

7. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

We did our best to explain what your rights are and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, do not worry, our Support Team will provide you with all the assistance you need when exercising your rights.

If you wish to exercise any of your rights below, please send us an email at support@awenetwork.com.

Our Support Team will provide you with information on actions taken within 30 days from the receipt of your request. Only in exceptional circumstances, when we face complex or a high number of requests, we may extend this period of response up to 60 days.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

7.1. Data access and data portability

You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge.

Upon verification of your identity, your request will be sent to our Support Team.

If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period of time), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you the information.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). For this purpose, you can send an email to support@awenetwork.com

7.2. Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can send an email to support@awenetwork.com.

7.3. Data retention and erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations.

If you no longer want us to use your information, you can request that we erase your personal information.

Your request will be sent to our Support Team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time

Please note that if you request the erasure of your personal information:

  • We might retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we close or suspend your account for fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information shall also be kept available in case of ongoing judicial proceedings/and or investigations.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that according to Luxembourg legislation financial related information shall be kept for a period of ten years.
  • Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  • In order to protect our site and your personal information from accidental or malicious loss and destruction, we have backup systems. Residual copies of your personal information may not be removed from our backup systems for a limited period of time.

7.4. Right to object

We process your data for a variety of reasons as explained in “WHY DO WE PROCESS YOUR PERSONAL DATA?”. Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to the use of your data might disable the use of your account.

Please note that you may, at any time, ask us to stop processing your data for any direct marketing activities.

7.5. Right to restriction of processing

You have the right to request that we hold your personal data in “limbo”, while other challenges are resolved.

Basically, you can ask us to put on hold the use of your data in 4 cases:

  1. If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.
  2. You have objected to a processing activity based on legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.
  3. You consider that the processing is unlawful but you object to erasure and request restriction, instead.
  4. We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

7.6. Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (in particular in the Member State where you live, place of work or of an alleged infringement of the GDPR).

8. CHANGES TO OUR PRIVACY POLICY

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the relevant app/site and/or contact you using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force. Your continued use of our site from that day on will be subject to the new Privacy Policy.

9. HOW TO CONTACT US?

If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to support@awenetwork.com or via mail to the address indicated below, and we will get quickly back to you. We are always glad to talk about our privacy practices.

Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at: dpo@awenetwork.com or mail to the following address:


To the attention of the DPO
Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg

This document was last modified: May 25, 2018