Privacy Policy

BoldWin – Privacy Notice

Last updated: May 2023

 

About this Privacy Notice

This Privacy Notice is meant to give you information about what personal data we collect about you, how we use it, why we use it, and how you control the data processing.

 

Table of Contents

  1. The Basics: Who We Are, Our Role, and Definitions
  2. Personal Data We Collect, How We Use it, and Why
    • Visitors to Our Website and Social Media Pages
    • Customers
    • Visitors to Publisher Assets
  3. Marketing Services
  4. Sharing the Personal Data We Collect
  5. International Transfers
  6. Security
  7. Your Rights – How to Control Our Use of Your Personal Data
  8. Data Retention
  9. Cookies and Similar Technologies
  10. Third-Party Services
  11. Children
  12. Changes to the Privacy Notice

 

  1. The Basics

 

  • Who We Are
    • Boldwin Ltd. is a global ad-tech company that operates and provides an online supply-side platform “. Our offices are located at Shvil Hameretz 4, Tel Aviv – Yafo, Israel, and our registration number is 515564979.
    • If you have questions about our company or your privacy, or want to exercise your rights, you can contact us at contact@bold-win.com or dpo@bold-win.com.
  • Our Role: Controller and Processor. Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a “controller”) and a party that processes personal data solely on the controller’s behalf and according to the controller’s instructions (called a “processor”). We are the controller with respect to the processing described in this Privacy Notice.
  • Definitions and Recommendations

 

  • When we refer to “services“, we mean services available through our platform.

 

  • When we refer to “personal data“, we mean information that is defined as personal data under law. This includes information that identifies you directly or indirectly, including unique identifiers like IP addresses or cookie IDs.

 

  • When we refer to “you“, we mean visitors to our website any user of our platform, or any visitor to the assets on which we place ads.

 

  • A Note on Legal Bases. Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU’s General Data Protection Regulation (“GDPR”), the possible legal bases include (but are not limited): your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data.
  1. Personal Data We Collect, How We Use It, and Why. Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don’t provide us with certain information, we may not be able to provide you with the associated services.

 

  • Visitors to Our Website and Social Media Pages.

 

  • Contact Form Information – When you send us a message through the contact form on our site, we collect any data you provide, such as your name, phone number, email, and the content of your message.

 

How We Use this Data: To respond to your message.

 

Legal Basis: We process this personal data based on the performance of a contract with you.

 

  • Activity and System Data (Cookies) – When you visit our site, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device ID, browsing history (e.g. the other sites you’ve visited before ours), and your activity on our site (e.g. what pages you visited, for how long, and what links you clicked on). For more information about the cookies we use and how to adjust your preferences, see the Cookies and Similar Technologies section below.

 

How We Use this Data: We mainly use this data to generate aggregated analytics data about the use of our site so we can maintain and improve the site and develop new products or services. We also use statistical data to prevent fraud and protect the security of our site. One of the tools we use to collect and analyze this data is “Google Analytics”. For more information about how Google collects information and how you can control such use, see: www.google.com/policies/privacy/partners/.

 

Legal Basis: We process this personal data based on our legitimate interests to develop and improve our products and services, and to prevent fraud.

 

  • Visitors to Our Social Media Pages – When you engage with our social media outlets, such as when you post on our Facebook or LinkedIn pages, like our posts, answer surveys, or similar activities, we collect the personal data you provide, such as the content of your post and the information available to us through your profile or account. The social media companies we use may also provide us with aggregate and analytical information about activity relating to us.

 

How we use this data: We may use this information to engage with you or respond to your posts and comments and to analyze the effectiveness of our social media efforts and to improve how we manage them.

 

Legal Basis: When we process your personal data to engage with you or respond to your posts and comments and to, we do so on the basis of our legitimate interest to engage with and serve our audiences in an effective manner. When we process your personal data to improve our social media outlets, we do so based on our legitimate interest to improve our services, and develop new ones.

 

 

  • Customers. If you represent a customer using our services, we collect basic contact details about you, including your name, email address, phone number, job title, and the company you represent.

 

How We Use this Data: We use this information to allow you to access our services and address, prevent fraud, and any issues that arise. We use your contact details to communicate with you about our services.

 

Legal Basis: When we process your registration data to provide you with our services, we do so to perform a contract with you, in this case our customer agreement. When we process your registration data to maintain our services, including to prevent fraud, protect the security of and/or address issues with our services, we do so on the basis of our legitimate interest to maintain our assets.

 

 

  • Visitors to Publisher Assets. Through our services, we enable third-party publishers to display online advertisements to end users who use or otherwise interact with certain mobile webpages and desktop websites of the publishers. In the course of providing the services, we collect the following personal data from such end users: IP address, device ID, user agent, and browsing history (e.g. the sites you visited before visiting the publisher’s site).

 

How We Use this Data: We mainly use this data in order to provide advertising services to our customers, including providing content that is targeted toward specific visitors by creating profiles and building lookalike audiences.

 

  • Legal Basis: We process this personal data based on consent contained by the publisher. You may withdraw your consent at any time by contacting the publisher directly. Additional information regarding Marketing Services is provided below.

 

  1. Marketing Services. As described above, we may use personal data we collect for advertising and marketing purposes as part of the services we provide to our customers.

 

  • Web Ads. We serve online ads based on the activity data we collect using cookies. You can change the way your browser manages cookies by adjusting the settings on your browser as explained below in the How to Adjust Your Preferences section.

 

  • Mobile Ads. Each mobile device is given a unique string of letters and numbers called a “Device ID.” Device IDs are retrieved by apps and used to perform various functions, such as to communicate with servers. We use Device IDs to serve you with ads. Device IDs can be used to track which apps were downloaded by the particular device as well as in-app activity on that device. This information, especially when combined with other identifying information, gives us insights into the preferences and interests of the owner of a given device and allows us to serve you with ads that we believe will appeal to you.

 

  • Android Advertising ID. We collect Android’s advertising identifier (AAID) from your device for advertising and user analytics only. We do not connect AAIDs to persistent device identifiers for advertising purposes. When we connect AAIDs to other personal data, we do so based on your explicit consent. When we use AAIDs for analytics purposes, we do not connect it with any other personal data. We use AAIDs in accordance with Google Play’s Ads Policy.

 

  1. Sharing the Personal Data We Collect. We share your personal data as follows:

 

  • Advertisers and Publishers. Data that is collected through publisher’s assets as part of our provision of the services may be shared with the relevant publisher or advertisers placing advertisements on such assets. Advertisers and publishers are able to combine the personal data they collect independently with personal data we share with them and are considered separate, independent controllers of such data. For more information about how these parties process your personal data, please contact them directly.

 

  • Service Providers. Below is a list of the types of service providers we use, the service each provides, and the types of data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct.

 

Type of Service

Description

Personal Data Shared

Cloud Computing

We use service providers that offer cloud computing services. They offer us space on their servers for us to store our files and programs, including your personal data.

All personal data that we collect from you through our site is stored on third party servers.

Customer Relationship Management (CRM)

We use an external CRM tool to help us keep track of our customers and information related to them, including their personal data.

Your name, company, position, email address, and phone number.

Analytics Providers

We use a service provider to assist us with analytics services.

Data collected automatically through our site, including IP addresses and cookie information.

 

 

  • Change of Ownership. If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice.

 

  • Law Enforcement Related Disclosure. We may share your personal data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements.

 

 

  1. International Transfers. Some of our service providers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.

 

  • If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area (“EEA“), we will ensure that they sign on agreements that require them to comply with applicable law, keep your data secure at similar levels to the level described in this Privacy Notice, and make sure that your data protection rights are protected. We will also implement the following safeguards:

 

  • When we transfer your personal data to Israel or the UK, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection.

 

  • Where we transfer your personal data to other countries, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your personal data the same protection it has in the EEA.

 

  • Please contact us at contact@bold-win.com or dpo@bold-win.com if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

  1. Security. The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords.

 

 

  1. Your Rights – How to Control Our Use of Your Personal Data. Depending on which laws apply, you have certain legal rights over your data. Below is some general information about rights that may apply to you but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at contact@bold-win.com or dpo@bold-win.com. If you want to exercise your rights regarding your personal data held by other controllers you can contact the applicable controller directly. We may ask for reasonable evidence to verify your identity before we can comply with any request.

 

  • Right of Access. You may have a right to know what personal data we collect about you. We may charge you a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your personal data is subject to GDPR.

 

  • Right to Correct Personal Data. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16 of the GDPR for more details, if your personal data is subject to GDPR.

 

  • Deletion of Personal Data (“Right to Be Forgotten”). If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your personal data is subject to GDPR.

 

  • Right to Restrict Processing. If you are located in the EU, you may have the right to ask us to stop processing your personal data. See Article 18 of the GDPR for more details, if your personal data is subject to GDPR.

 

  • Right to Data Portability. If you are located in the EU, you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly-used, and machine-readable format. See Article 20 of the GDPR for more details, if your personal data is subject to GDPR.

 

 

  • Right to Object. If you are located in the EU, you may have the right object to certain processing activities. See Article 21 of the GDPR for more details, if your personal data is subject to GDPR.

 

  • Withdrawal of Consent. If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won’t affect processing we have done from before you withdrew your consent.

 

  • Right to Lodge a Complaint with Your Local Data Protection Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

 

  1. Data Retention.

 

  • We retain your personal data as long as necessary to fulfill each of the purposes we described above. Once we’re done with your data, we delete it.

 

  • When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which the personal data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business’s retention policy.

 

  • Representative

    We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

    • United Kingdom (UK)
    • European Union (EU)

    Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:https://app.prighter.com/portal/bold-win

 

  • Please contact us at Website if you would like details about the retention periods for each type of personal data we process.

 

 

  1. Cookies and Similar Technologies.

 

  • What are Cookies? A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a sort of tag, letting the website know that it’s you (really, your device) that’s visiting. There are other technologies that act similarly, like web beacons, pixel tags, and Device IDs for apps, but for simplicity’s sake we’ll refer to them all as “cookies”.

 

  • Websites can place their own cookies (called “first-party cookies”) but can also place cookies from other sites (called “third-party cookies”). If your browser holds both first and third-party cookies for a given website, both the website and the third party are notified when you visit the site. We may place both first and third-party cookies on our site.

 

  • How We Use Cookies on our Site. While the specific names and types of cookies we use on our site may change from time to time, they generally fall into one of the categories listed below.

 

Cookie Type

Function

Necessary

These cookies allow our site to work correctly. They enable your access our site, move around, and access different services, features, and tools. These cookies cannot be disabled.

Functionality

These cookies remember your settings, preferences, and other choices you make in order to help personalize and streamline your experience.

Security

These cookies help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.

Performance/Analytics

These cookies collect analytical information to help us understand how you use our site, for example whether you have viewed messages, clicked on links, and how long you spent on each page. This helps us improve our site to better suit your needs.

 

  • Third Party Cookies. In addition to our first-party cookies, we place cookies from the following third parties:
  1. Google Analytics
  2. TC string

 

 

  • How We Use Cookies in Our Services. In the course of providing services to our customers, we place advertising cookies on publisher assets. These cookies help advertisers show you ads. When we place advertising cookies, they help us track the efficiency of advertising campaigns. Advertising cookies may track your browsing habits and activity when visiting the publisher’s assets and those of third parties and help us serve ads that are relevant and meaningful to you and your interests.

 

  • How to Adjust Your Preferences. Most web browsers are initially configured to accept cookies, but you can change the settings so your browser refuses all cookies or certain types of cookies. In addition, you are free to delete any existing cookies at any time. Please note that some features of the services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.

 

  • By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. This means that you won’t be shown ads that relate to your browsing activities. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device. Adjusting your preferences does not mean you will no longer receive ads, it only means the ads that you do see can be less relevant to your interests.

 

  1. Third-Party Services. You may have access to third-party services through our services. Please note that all use of third-party services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.

 

  1. Children. We do not knowingly collect personal data from children for whom parental consent would be needed for such collection. In the event that you become aware that an individual for whom parental consent is needed has visited our site and/or used the services, please advise us immediately. The relevant age varies per jurisdiction and is usually between 13-16 years.

 

  1. Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version.

CONTACT US
If you have any questions or comments about this Policy, please write to us at:
Boldwin LTD
Shvil Hamerez 4, Tel Aviv, 6653520, IL

You can also contact us via email at: dpo@bold-win.com, contact@bold-win.com