Privacy Policy

Last updated: 17 MARS 2019

Cindy Dev takes your privacy very seriously and fully complies with the new European Data Protection Regulations (General Data Protection Regulation – GDPR). This Privacy Policy governs and details the main privacy principles Cindy Dev (“we,” “us,” “our”) applies to the data we collect and process through our advertising services, i.e. to the data collected from the end user seeing the advertising (“you”, “your”). This Privacy Policy describes how Cindy Dev collects, uses, shares and secures personal information through our advertising services, and also describes your choices regarding our use and your access to your personal information.

For privacy policies regarding the use of the Cindy Dev please read the Website Privacy Policy.
What does Cindy Dev do?

Cindy Dev is the company behind the world’s most advanced Artificial Intelligence-powered user classification technology. As ads move through the programmatic supply chain, Cindy Dev aligns the ROI interests of the demand and supply side by creating a unified insight in understanding and valuation of consumer behavior.
The makes advertising more relevant for consumers and allows publishers to offer content for no or lower costs. The platform was built in Germany with user privacy at the core of its design from day one. Therefore, it complies with European Data Protection Regulations (General Data Protection Regulation – GDPR) and applicable national data protection laws.

Cindy Dev processes your information in order to ensure advertisers can provide you with relevant advertising based on your interests, affinities and local context and measure the effectiveness of their campaigns. The aim of this is to effectively reduce the amount of ads you see that aren’t beneficial or of interest to you. An opt-out from targeting would not reduce the amount of ads, it just makes the ads you receive less relevant.
What information do we collect and why?

The information described below is not initially collected by Cindy Dev but instead is submitted to the Advertising Platform by some of our clients and partners to be available on the Advertising Platform.

 At Cindy Dev , we fully respect your right of informational self-determination. Therefore, we require our clients and partners to satisfy all transparency disclosure and consent requirements to enable Cindy Dev to process the following information for the purposes listed below. It includes data generated through the platform as well as data clients receive from other sources and then used on the platform. None of the information (technical and all other information) submitted to Cindy Dev is personally identifiable information (PII). It is not possible for Cindy Dev to identify individuals via the information collected by the Cindy Dev platform. The collection and use of that consumer information is governed by the privacy policy and legal terms of the data collector using the data; it is not governed by Cindy Dev .

Types of information

    Mobile Advertising ID
    Location Data
    Cookie Information
    IP Address
    App usage information (as submitted from Cindy Dev ’ clients, e.g. number & timing of sessions)
    Demographic Data (as submitted from publishers displaying our advertising)
    Audience Segments

Why we use it

Cindy Dev uses this information for online marketing purposes throughout its Advertising Platform.
In detail, we use the information to

    Predict users’ interests and preferences for interest-based advertising
    Enable advertisers to customize ads to users’ behaviour
    Determine how users respond to certain ads
    Report aggregated statistics regarding, for example, the effectiveness of digital advertising campaigns and
    Provide, operate, manage, maintain, and enhance the Advertising Platform.

Data being submitted to Cindy Dev from our clients and partners uses pseudonymous identifiers associated with your mobile device rather than names, email addresses or phone numbers. In addition to this, Cindy Dev utilizes hashing, encryption and de-identification techniques to help ensure your privacy is safeguarded at all times when data is shared with third parties. Cindy Dev enforces generally accepted industry security standards on the Advertising Platform to protect the information both during transmission and once it is received.
Legal basis for processing (EEA visitors only)

If you are a visitor from the European Economic Area (EEA), our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. We collect and process information from you only where we have your consent (Art. 6 para 1 lit. a) GDPR), where we need the information to provide our contractual obligation to you (Art. 6 para 1 lit. b) GDPR) or where we have a legitimate interest to do so.

If you wish to learn more about specific legal ground(s) we rely on to process your information for any particular purpose (including any legitimate interests we have to process information), then please contact us using the details provided below under “Contact Us”. However, by way of example, we rely on our legitimate interests to process information for direct marketing purposes and for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms (Art. 6 para 1 lit. f) GDPR).
Who do we share your information with?

We disclose your information to the following categories of recipients:

    To our affiliate and third-party services providers who provide data processing services to us and support us in providing our services (for example, to send us data or to deliver the advertising) or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information,
    To our clients and partners to deliver interest-based advertising and other information describing e.g. location context and general statistical information,
    To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person,
    To a potential buyer (and its agents and advisors) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;

How long do we keep your information?

We retain personal information we collect from you as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

In any event, information that is transferred to us by our clients and partners will be deleted after a maximum period of three months or earlier if our clients and partners select to delete and update their data on the Advertising Platform more often.
Your data protection rights

You have the following data protection rights:

    If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Contact Us” heading below.
    In addition, if you are subject to European Data Protection Regulation, you can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Us” heading below.
    You have the right to opt-out from our marketing communications at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “Contact Us” heading below.
    Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.) We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Contact Us :

If you have any questions or concerns about our use of your personal information or if you have questions about privacy on the Advertising Platform, please contact us at: divlopcindy@gmail.com.

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