End-User
Privacy Policy

Effective date: May 25, 2018

Last updated: May 22, 2018

This document provides information about our
advertising technology platform, Offerwall Ads. Offerwall Ads (Central Lofts, 5 Waterloo square, Newcastle
Upon Tyne, NE1-4DR) enables advertisements to appear within desktop and mobile
websites. The intention of this document is to provide you transparent
information how the Offerwall Ads platform runs and
how the data is processed, collected, and stored in the platform. We realize
that some technical terms might sound complicated to you, so this document
presents those terms in simple words as well as explains what the goal of data
processing is.

Offerwall Ads is firmly committed to
protecting the privacy of Internet users and fostering users’ confidence in
online advertising and marketing. Accordingly, we are committed to observing
applicable industry guidelines including those established by the Interactive
Advertising Bureau and the General Data Protection Regulation (“GDPR”) by the
European Union. We continue to evaluate enhanced ways to protect Internet
users’ privacy while seeking to deliver relevant advertising and custom online
experiences to those users on behalf of our customers.

This document outlines Offerwall
Ads’s End User Policy and provides you a clear notice
about the user information we may collect and process online in connection with
our services.

Our customers use our technology (Offerwall Ads available at http://www.offerwallads.com/privacy-policy/ to execute advertising
campaigns. Such operations result in you having indirect (when
advertisements are displayed within sites and apps) and direct (when you click
any of these advertisements) interactions with our servers.

I. Glossary

  • Applicable
    laws
    : All
    the laws and regulations relevant to the collection, processing, and
    storage of data, especially all the data protection laws and the General
    Data Protection Regulation (EU) 2016/679(GDPR).
  • Ad
    exchange
    :
    This is a platform where people who can offer unsold ad placements meet
    people who want to buy those placements for their online advertisements.
    You can think about it as a digital marketplace with a sort of an auction
    called real-time bidding. However, a buyer can be anybody including other
    ad exchanges or platforms that sale advertisements to other companies /
    buyers.
  • Ad
    server
    : By
    and large, a server where advertisements are stored and managed, and
    delivered to you as a website end user. It might also provide a
    reporting module to check how the advertisements perform.
  • Customer: The party who submits an
    application on one of the registration pages: http://www.offerwallads.com/privacy-policy/
     and uses the Offerwall
    Ads platform.
  • Domain
    name
    : It
    is a character string that helps you to easily go to a website without the
    necessity of remembering IP addresses. A domain name must be unique for
    all domain names available on the Internet. It allows you to navigate to a
    website and discover an online advertisement.
  • End
    user (visitor)
    :
    This is a user of an Internet connected device, such as a visitor to a
    website, a user of a mobile app, or a user of an IoT device, or a visitor
    on an advertisement, landing page, or campaign.
  • Geographic
    location
    :
    This is a piece of information where you are located based on an IP
    address. Precisely, this is a location of your device that is connected to
    the Internet and based on that we are able to define a country, region,
    city, and Internet Service Provider (ISP) your device is connected to.
  • HTTP
    request header
    :
    The request header of HyperText Transfer
    Protocol. The HTTP protocol is used all around the world. Almost
    all content that shows up in the browser you see is transmitted to your
    computer (or other device connected to the Internet) over HTTP. For
    example, when you opened this policy in the browser, many HTTP
    requests have been sent. Each request contains an HTTP header in which
    there is information about the browser you use, the requested page, the
    server and much more.
  • IP
    address
    : An
    Internet Protocol (IP) address is a set of numbers that each device
    has assigned to connect with other device over the Internet network. The
    IP address allows addressing and delivering the information to the right
    receiver. Every time a piece of information is sent, a device needs to
    communicate with other devices in a computer network to be able to deliver
    the message. Sending information in that context means every kind of
    activity such as surfing, exchanging emails, or downloading an
    application. The IP address is used to identify the device to which
    the message is supposed to be sent and find the best way to deliver it.
  • Personal
    information / personal data
    : Any information relating to an
    identified or identifiable person as defined in article 4.1 of GDPR.
  • Processing: Any operation or set
    of operations which is performed upon personal data, whether or not
    by automatic means, such as collection, recording, organization, storage,
    adaptation or alteration, retrieval, consultation, use, disclosure by
    transmission, dissemination or otherwise making available, alignment or
    combination, blocking, erasure or destruction (process, processes
    and processed shall have the same meaning).
  • Real-time
    bidding
    : Offerwall Ads’s customers
    are able to bid in real time to get the opportunity of showing an online
    advertisement offered by a certain ad exchange. The winner of the auction
    is treated as the best candidate to display the advertisement on a
    website.
  • Referrer
    domain
    : In
    simple words, this is the address of a website that led you, as a
    visitor, to another page.
  • Targeting: A strategy of online
    advertising when information is gathered to address visitor’s preferences
    based on the collected data. When you as a visitor go to websites in one
    particular language, then the advertisement is displayed in front of you
    in the same language you were browsing and relates to the region you are
    located.
  • User
    agent
    :
    Information about a device, operating system, web browser is being used to
    access a website.
  • You
    (visitor)
    : A
    person who can visit digital advertising campaigns on the Internet.

II. What is Offerwall
Ads?

Offerwall Ads is a real-time bidding pop
and domain traffic network. This means that Offerwall
Ads connects one group of customers (publishers) looking to monetize their
websites with other group (advertisers) that want to sell items or services to
the visitors of these websites. Offerwall Ads enables
the advertisers to get traffic from publishers’ parked domain redirects to
advertisers’ landing pages or via new browser windows popping-up on publishers’
websites and displaying an advertisement.

There is a number of advertisers willing to score
each display of an advertisement. To determine whose ad gets displayed, an
auction is held. It takes place as a visitor loads the page, so it usually
takes about milliseconds. In that time all interested advertisers automatically
put their predetermined bids, the highest of which wins the bidding, resulting
in displaying an ad.

In the next sections you can find out what
information is stored in Offerwall Ads and how it
relates to your activities as a visitor.

III. Offerwall
Ads’s Role in Processing Personal Information

While our customers use Offerwall
Ads, we act as a customer’s data processor meaning that we process end user’s
personal data on behalf of our customer under customer’s instructions.

IV. What Kind of Data Do We
Collect and For What Purposes?

In order to perform our services
we are intent to collect and process certain information about you and your
device. Some of this information, for example your IP addresses, may identify a
particular computer or device and be considered as “personal data” in some
jurisdictions, including the European Union. This kind of data enables us to
provide aggregated reporting and analysis of the performance of our customer’s
advertising campaigns.

The Offerwall Ads
platform does not collect any data which by itself identifies an individual
such as name, address, phone number, email address.

We also do not collect any “sensitive” or “special
categories of personal data” as defined under European data protection laws as
well as personal data of children.

IP Address

An IP address is used to identify the device’s
location as well as, to some extent, user’s location. Based on the IP
address visitor’s country, region, or city can be characterized and stored in
the Offerwall Ads platform. Moreover, some more
technical specifications are processed such as Internet Service Provider (ISP).
This data is stored to adjust the online advertisements that are displayed on
websites and identify automatic computer programs that might affect our
customers’ reporting.

In addition, the IP address is used to limit the
number of times a visitor is exposed to a single advertisement.

User Agent

A user agent helps us to identify what kind of a
device a visitor uses (TV, desktop, table, mobile phone) and which model it is.
Even more, this piece of information is stored to establish device’s
parameters such as browser and browser version, operating system, and operating
system version. It also allows us to detect the automatic computer programs and
fraud attempts.

Additionally, the user agent is used to limit the
number of times a visitor is exposed to a single advertisement.

HTTP Request Header

The HTTP request header is used for troubleshooting
purposes to fix customer’s issues with campaign’s settings.

Device ID

A device ID is a unique identifier used to
accurately measure actions taken by a specific device. It plays a role in
personalization, distribution, and performance of the traffic sent to a
visitor.

Domain

Information about a domain is stored to be able to
determine whether a domain is fake or not. Moreover, it helps to find
a specific category of a website that is related to a customer’s
advertisement. This allows displaying advertisements where their topics are
very close to the topic of the website visitors see in front of them. The
domain information is also used for reporting and troubleshooting purposes.

Referrer Domain

The referrer domain data is stored for
troubleshooting purposes as well as used to define whether a website is
addressed to an adult audience. This helps to display the advertisement always
to a proper audience.

Keywords

Defining keywords and targeting by them is a
popular form of online advertising when customers want to address their
advertisements to people who are looking for such keywords on the Internet. Offerwall Ads helps them to define those keywords and, once
defined, store them in the platform. Keywords are also used when it comes to
troubleshooting to sort out issues with campaign’s settings.

Note that our publisher partners may share with us
additional demographic information, such as age or gender, in order to enable
more accurate targeting. We do not use this information to maintain any kind of
persistent user profile database.

V. How Do We Collect Data?

The Offerwall Ads
platform uses non-cookie technologies to collect data associated with
particular web browsers or devices that you as a visitor use. The Offerwall Ads platform does not use cookies to collect data
about visitors of advertisements.

Offerwall Ads collects end user’s data
being sent either by a publisher or through third-party partners. This data
consists of an IP Address, User Agent, Referrer, Accept Language, all HTTP
Headers, and Keywords.

Whenever Offerwall Ads
wins an auction and customer displays an ad from Offerwall
Ads, the IP Address, User Agent, Referrer, Accept Language, all HTTP Headers
are also retrieved from end user’s browser request sent to Offerwall
Ads.

VI. For What Purposes We Use End
User Data?

The data collected and stored in the Offerwall Ads platform is used by Offerwall
Ads’s customers to increase the ad relevance and
target different kinds of audiences. Particularly, our customers use Offerwall Ads for:

Adult Visit Detection

To check a type of an audience (adult or non-adult)
and display an advertisement only to the proper one.

Fake and Duplicated Traffic
Detection

To monitor the quality of traffic for our customers
and blacklist those sources that generate fake or duplicated visits / clicks.

Fake Domain Detection

To detect domains that might look like an
original domain of the customer and abuse the domain’s reputation for different
sorts of benefits.

Frequency Capping

To limit the number of times a visitor is
exposed to a single advertisement.

Geo Targeting

To allow the Offerwall Ads’s customers to address visitor’s preferences that refer
to a geographic location. The targeting is mainly based on a country, Internet
Service Provider, or demographic data.

Optimization

To measure the effectiveness of online ad campaigns
what helps to address the advertisements to right audiences and based on the
collected data improve the performance of the campaigns. Briefly, to determine
how visitors respond to advertisements they see on the Internet. The goal of
the optimization is helping advertisers predicting the cost of a particular
campaign and find an optimal value.

Reporting

Reporting aggregates data for troubleshooting,
analysis, improve our customers’ experience, provides custom reporting for both
publishers and advertisers.

Targeting by Keywords

To choose words that are relevant or
important to a displayed advertisement to be able to target end users searching
for the same terms.

Troubleshooting

To fix technical issues that Offerwall
Ads’s customer experience while running their online
campaigns and identify faulty settings of the configuration.

VII. Legal Basis for
Processing User Information

For our customers, meaning both advertisers and
publishers, we collect and process end users’ personal data as their data
processor. If you are a European Union End user or GDPR applies to you under
Applicable Law, our customers need to have a legal basis for collecting and
using the end user information described above. The kind of legal basis used by
our customers will depend on the user information concerned and the specific
context in which we collect it. Mainly, this legal basis is end users’ consent
in particular when end users’ personal data is collected and processed in order
to deliver targeted advertising to the end user.

Sometimes, end user’s data can also be processed
under legitimate interests of our customers, in particular to:

  • Operate
    and improve our technology
  • Enable
    standard advertising controls
  • Prepare
    reports that summarize visitor’s activity
  • Analyze and report on the advertisement’s performance
    (such as tracking views of ad as well as click-through rates on ads),
    campaign reporting, and campaign forecasting
  • Protect,
    investigate, and deter against fraudulent, unauthorized, or illegal
    activity.

VIII. How Long Do We Store Data?

The collected data is stored using generally
accepted security standards. The data retention of visitor’s activities in the Offerwall Ads platform is 3 months starting from the day of
the customer’s account registration. This data is used for reporting and
analysis. After 3 months, all collected data regarding visitors is removed.

IX. Your Choices and Opt Out Option

The opt out option is applicable for end users who
see an online advertisement set by a customer.

If you wish to opt out of being tracked
with desktop and mobile website environments from Offerwall
Ads, please email dpo@Offerwallads.com.

Opting out of being tracked with desktop and
mobile website environments from the Offerwall
Ads platform is valid for 10 years for a web browser where the opt out option
has been set. The option can be enabled only for a particular web browser
meaning that if you switch to start using other web browser, make an update for
the current version of the web browser, clear cookies, or use a browser’s
incognito mode, you need to go through the opt out procedure once more. When
the opt out option expires, you need to repeat the same procedure to turn it on
again.

X. European Data Subject
Rights

If you are a European Union end user or GDPR
applies to you under Applicable Law, you have certain rights and protections
under the law regarding the collection, processing, and use of information
about you. In particular, you have the right to:

  1. To
    request access and obtain a copy of your data.
  2. To
    request rectification (correct or complete information about you) or
    erasure (it is sometimes called ‘the right to be forgotten’ that applies
    in some circumstances).
  3. To
    restrict the processing end user information.
  4. If
    applicable, to the data portability.

In certain circumstances, you may also have the
right to object to the processing of end user’s information when personal data
is processed on the basis of legitimate interests and there is no overriding
legitimate interest for us to continue to process your personal data, or if
your data is being processed for direct marketing purposes.

If you have given us your consent to process your
data, you have the right to withdraw your consent. The withdrawal of consent
does not affect the compliance of the processing which was made on its basis
before the withdrawal of consent.

You have also the right to lodge a complaint with
the Supervisory Authority in particular if you feel that Offerwall
Ads has not responded to your requests to solve a problem.

As we act as a processor of end users’ personal
data on behalf of our customer, according to GDPR, taking into account the
nature of the processing, we are obliged to assists the controller by
appropriate technical and organisational measures, insofar as this is possible,
for the fulfilment of the controller’s obligation to respond to requests for
exercising the data subject’s rights laid down in GDPR.

In aforementioned matters, please contact our data
protection officer: DPO@OFFERWALLADS.COM.
Please include information that will enable us to verify your identity within
your request.

XI. Transfer of Personal
Data Outside EEA

We work with customers and partners throughout the
world, including in the European Economic Area (EEA) as well as countries
outside of the European Economic Area (EEA).

In order to ensure that your personal data is
adequately protected when transferred outside of the EEA, Offerwall
Ads:

  • relies on
    EU-U.S. Privacy Shield Program – Privacy Shield is a “partial” adequacy
    decision, as, in the absence of a general data protection law in the U.S.,
    only the companies committing to abiding by the binding Privacy Shield
    principles benefit from easier data transfer. In such cases, your personal
    data will be transferred to the territory of USA in accordance with
    applicable laws, with appropriate safeguards in place, only to Privacy
    Shield certified vendors (according to the EU Commission Decision
    2016/1250), or by using standard contractual clauses adopted by the
    European Commission (EU Commission Decision on standard contractual
    clauses for the transfer of Personal Data to processors established in
    third countries under Directive 95/46/EC (the “Model Contract Clauses”),
    or based on other applicable transborder data transfer mechanisms,

or

  • has
    entered into inter-company EU “model clause” agreements.

You may contact us if you require a copy of the
safeguards which we have put in place to protect your data transferred outside
of the EEA and your privacy rights in these circumstances.

You may also learn more about:

XII. Security

Offerwall Ads uses various security
technologies and procedures that help protect your personal information from
unauthorized access, use, disclosure, alteration, or destruction.

For example:

  • Personnel: Only qualified and
    authorized employees are permitted to access personal information, and
    they may do so only for permitted business functions.
  • Data
    Protection Officer
    : We appointed a Data Protection Officer
    who in particular watches over the security of your data, monitors our
    compliance with GDPR, and is a point of contact for you in all matters
    regarding data protection; here you have contact to our Data Protection Officer: : DPO@OFFERWALLADS.COM.
  • Security
    Measures
    : We
    use encryption in the transmission of your personal information between
    your system and ours, and we use firewalls to help prevent unauthorized persons
    from gaining access to your personal information.
  • Payments: All supplied
    sensitive/credit information is transmitted via Secure Socket Layer (SSL)
    technology and then encrypted into our payment gateway providers database
    only to be accessible by those authorized with special access rights to
    such systems, and are required to keep the
    Information confidential. After a transaction, your private information
    (credit cards, social security numbers, financials, etc.) will not be
    stored on our servers.
  • Additional
    Safeguards
    : We
    maintain physical, electronic and procedural safeguards in connection with
    the collection, storage and disclosure of your information. Our security
    procedures mean that we may request proof of your identity before we
    disclose personal information to you.
  • Trusted
    Vendors:We
    rely only on vendors who ensure an
    appropriate level of security of your Data. In this context, we use only
    secure cloud servers, including AWS cloud – a secure, private cloud
    platform. AWS participates in the EU-US Privacy
    Shield framework. Amazon Web Services is our processor. AWS Amazon
    cloud platform uses various security technologies and procedures to
    protect personal data and is compliant with third-party assurance
    frameworks such as ISO 27017 for cloud security, ISO 27018 for cloud
    privacy, PCI DSS Level 1, and SOC 1, SOC 2, and SOC 3. For more
    details please see AWS Amazon security and privacy policy at
    www.aws.amazon.com.

XIV. Children

Protecting children’s privacy is very important to Offerwall Ads. Our platform is not intended for, designed
to be used by, or targeted at children. We do not allow our partners and
customers to send to us personal data of children as defined under GDPR.

XV. Contact Us

If there are any questions regarding this End User
Privacy Policy, you may contact us using the information below:

Offerwall Ads

Central Lofts

5 Waterloo square

NE1-4DR