Introduction

Adzooma (“we” or “us”) are committed to protecting and respecting your privacy. Adzooma takes care to ensure that the information you provide to us is protected and managed in accordance with the requirements of all relevant Data Protection Regulation.

This Privacy Policy (together with the other documents in the Terms and Conditions) explains how we use the information we collect about you, your rights under applicable data protection legislation and the procedures we have in place to safeguard your information.

By using our Services, you indicate that you accept this Privacy Policy. If you do not accept this Privacy Policy, you should not use our Site.

Data Controller

Adzooma is owned and operated by ClickTech Solutions Ltd., located at St, James’ Place, 7 Castle Quay, Castle Boulevard, Nottingham, NG7 1FW, United Kingdom.

Information we may collect about you

When you create an account with Adzooma, we are required to collect some information on you before you can use Our Services. Our records may include all or some of the following information about you:

• Your name, address, email address, telephone number, payment card details, etc.
• Details of your correspondence with Adzooma and any other information you have given to us.
• Details of your transactions and other activities carried out on Our Services.
• Details of your visits to our websites and/or Apps including, but not limited to, traffic data, location data, IP address, device ID, web logs, page views, ad data and other similar data, whether this is required for our own purposes or otherwise; and
• Your response to marketing campaigns from us or through our third parties.

How we may use information about you

Adzooma may use information held about you in the following ways:

• To help us identify you and any accounts you hold with us.
• To enable us to comply with legal and regulatory requirements.
• To provide you with our products and services.
• To make our websites and services easier to use by removing the need for you to enter repeatedly the same information.
• To operate and improve our websites, Apps and services and to notify you of any changes to our websites, our products and services and/or Apps which may affect you.
• To perform research and analysis aimed at improving our products and services.
• To enable us to offer you products and services customized to your preferences.
• Subject to any applicable preferences, to enable us and our partners to send you promotional offers relating to our products and services and
• To carry out profiling and analysis based upon behaviour in order to:
  • provide tailored marketing and offers
  • comply with legal and regulatory obligations
  • to manage risk and prevent fraud

We may anonymise the personal information that we hold about you so that it can no longer be associated with you, in which case we may use such information without further notice to you. This is so that we can compile, analyse and disclose to third parties aggregated metrics, data and trends related to the use of Adzooma’s offerings.

Legal Basis for Processing

Our lawful basis for processing personal data include:

• To fulfil a contract we have with you.
• When it is our legal duty to do so.
• When it is in our legitimate interest.
• When you consent to it.

Sharing your information

Subject to relevant data processing agreements, and in full compliance with data protection regulation, Adzooma may share your personal data with:

• Members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, together with their employees or agents;
• Third party marketing services;
• To verify your identity and risk profile;
• To monitor your account for security purposes;
• To offer you services on our platform;
• To process your payments;
• Law enforcement agencies or regulators in accordance with legal requirements; and
• To potential purchasers or investors.

Marketing and opting out

• Subject to appropriate, applicable consent we may contact you via email, SMS, Telephone or post.
• These marketing messages will provide you with information about our own products and services.
• If you do not want to receive offers from us, you can stop the delivery of promotional emails, postal mail and other types of promotional communications from Adzooma by:
  • Changing your marketing preferences in your Adzooma account, if you are an existing customer;
  • Following the specific instructions in any email that you receive;
  • Contacting us via help@adzooma.com and asking to be removed from our marketing lists; or
  • Via your browsers and applications, where you can control notification settings.

Monitoring and use of cookies

• Adzooma may obtain information about your use of its Services by using web beacons and by placing a cookie, which is a small file, on your mobile device and/or computer’s hard disk. We use two types of cookies:
  • Functionality Cookies – these cookies recognize you whenever you visit our websites or Apps and remember your user preferences. They also speed up access to our websites and the Apps (so you do not have to login each time).
  • Advertising Cookies – these cookies are used to build a profile about you so that our marketing and advertising campaigns are more relevant to you.
• Using our Services will constitute acceptance of use of Cookies.
• Many web browsers automatically accept cookies, others may not. However, you can change your browser settings to either accept or reject cookies, according to your preference. If you do not accept cookies, you may lose some of the functionality of our websites and/or Apps. If you need more information about cookies such as what they do, how they work and how to enable/disable them, please go to www.aboutcookies.org
• Please note that our advertisers and other partners may also use cookies, over which we have no control. Adzooma may monitor and record its communications with you (such as telephone conversations and emails) for the purposes of quality assurance, training, fraud prevention and compliance.
• You can read more about cookies on our cookie policy page

Data security

• Adzooma takes the security of your data very seriously. We will take appropriate security measures against unlawful or unauthorised processing of your information, and against the accidental loss of, or damage to, your information. Our objectives are:
  • Confidentiality – only authorised people can access the information.
  • Integrity – information should be accurate and suitable for the purpose for which it is processed.
  • Availability – authorised users should be able to access the data if they need it for authorized purposes.

Subject Access Request

• You are entitled to a file a Subject Access Request (SAR) to obtain a copy of the personal information which we hold about you. In order to submit a Subject Access Request, please email help@adzooma.com with “FAO: Data Protection Officer – Subject Access Request” in the subject line. In the email body, please include the following:
  • Your full name
  • Address (as registered on your Adzooma account)
  • Contact telephone number
  • Specifics of any exact details which you wish to receive (for example, copies of emails sent or received)
• The requested information will be provided within one calendar month of the Subject Access Request being received by Adzooma. If for any reason Adzooma cannot meet this deadline (for example, if the requests made are numerous and complex), you will be informed of this within the initial one-month window, with an explanation as to why the data has not been provided, and a firm estimate of when the data will be collated and prepared for sending to You.

Data retention

• We will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.
• You may request that your Personal Data be anonymised in the following circumstances:
  • Where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed.
  • When you withdraw consent, if consent is being used as the Legal Basis for Processing.
  • If you object to the Processing and there is no overriding Legitimate Interest or Legal Obligation to continue the Processing.
  • The Personal Data was unlawfully processed.
  • The Personal Data has to be erased to comply with a legal obligation.

Transfers of data out of the EEA

• We will not transfer Personal Data to recipients in Third Party countries that are outside of the EEA, or are not currently recognised by EU law as having an adequate level of legal protection for the rights and freedoms of data subjects unless:
  • the Processor is certified under the EU-U.S. Privacy Shield Framework.
  • the existence of any other specifically approved safeguard for data transfers (as recognised under EU Data Protection Laws) and/or a European Commission finding of adequacy can be demonstrated.

Third party websites

Our websites and the Apps may, from time to time, contain links to the websites of our partners; networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

AGENCY CLIENTS

For those clients of ours who are an Agency (as defined by the Adzooma Terms and Conditions) we will be a data processor of the Customer Data that you provide.

Data processor

Adzooma is owned and operated by ClickTech Solutions Ltd., located at St, James’ Place, 7 Castle Quay, Castle Boulevard, Nottingham, NG7 1FW, United Kingdom.

Information We May Collect On Your Customers

When you create an account with Adzooma and are an Agency Client, Our records may include all or some of the following information about your customers:

• Their name, address, email address, telephone number; and
• Aggregated metrics, data and trends.

Sharing your Customers’ information

We may share your Customer’s information with:

• Members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, together with their employees or agents
• To offer you servicesƒ on our platform

We will not share your Customer Data with other customers or third parties.

How we may use information about your Customers

Adzooma may use information held about your Customers in order to compile, analyse and disclose to third parties aggregated metrics, data and trends related to the use of Adzooma’s offerings provided that these metrics, data and trends do not contain uniquely identifiable data about your customers.

Data Retention

We may retain the data from your customers that we have anonymised and which we have used to identify aggregated metrics, data and trends for as long as those metrics, data and trends are necessary and relevant in informing third parties or our other customers of marketing trends.

Contact

We welcome your questions and comments relating to this Privacy Policy. We can be contacted via email at help@adzooma.com or in writing at Adzooma, St. James’ Place, 7 Castle Quay, Castle Boulevard, Nottingham, NG7 1FW.

This privacy policy is created, controlled, and maintained by the Data Protection Officer (DPO). If you wish to contact the DPO in order to discuss how we handle and process your personal data (or to submit a Subject Access Request as discussed in the “Your Rights” section of this policy), the DPO can be contacted through the below address;

The Data Protection Office
Adzooma
St. James’ Place
7 Castle Quay
Castle Boulevard
Nottingham
NG7 1FW

If you are unhappy with how we have used your personal information then please let us know, so we can launch an investigation. You also have the right to complain to the Information Commissioner’s Office.