Website Privacy Policy - Improve Digital

Improve Digital Website Privacy Notice

We at Azerion Technology B.V. (“Improve Digital”, “we”, “us” or “our”) respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when use our website including our platform (“Website”) which helps our clients to monetise their advertising spaces, buy and sell online ads through online programmatic auctions and classic deals. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you use our Website or any of other services, all of which together we refer to as “Services“.

Please note that the explanations provided in this Privacy Notice relate exclusively to the processing of personal data regarding our games and our Services. When you visit Third Party Platforms they may be collecting your personal data for their own purposes. If you would like to learn more about the privacy practices of the respective partner websites through which our games are provided, please review the Third Party Platform website’s privacy statement.

General Information

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

1. Who is responsible for the processing of your Personal Data

We, Azerion Technology B.V., based at Boeing Avenue 30, 1119 PE Schiphol-Rijk, the Netherlands responsible (“the data controller”) for the processing of your Personal Data when you use our Website.

2. What types of Personal Data do we process and how do we collect it?

When you use our Website, as further explained, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data:

2.1. Personal Data provided by you

When you use our Services, you provide or be asked to give us certain information, including:

Information provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details (your name and email).
Account information: If you create an account to access our platform, we collect your log-in data (your email address, username and password).
Information provided in relation to transaction and payment: We collect your (if you are a Publisher) billing information payment type, currency, depositor detail (company name, your name and surname if you are private person ), street and house number street name and house number, postal code, city and country), bank details (bank name, account number/IBAN, swift code, bank address) in order to make you payment.

2.2. Personal Data we receive from your use of our Services

When you use our Services, we also process device-related information and information about how you interact with our Services, including:

Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), game/site ID, geolocation data (based on your IP address), browser settings, screen resolution and other technical information.
Cookie data: A “cookie” is a file of information placed on your device when you visit a website. As further described in our cookie notice (“Cookie Notice“) below, we use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice.

2.3. Personal Data we collect from third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data are provided by the following third parties, including:

Your Consent String: When you visit our Website, our consent management platform (CMP) provider obtains your consent for our processing activities as well. The CMP provides us with your consent string which shall indicate your preferences on our respective processing activities.

To learn more about which data is processed, please see the section with service specific information below.

3. Do we collect data from minors?

Our services are intended to be appropriate for general audiences. Therefore, we do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team.

4. For what purpose do we process your data?

When we act as a data controller, depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

4.1. Provision and improvement of our Services

to provide our services
to allow you to use our Website
to create and manage your account
to restore your account if you ever lose access
to communicate with you in context of account activation, password management
to simplify the registration process,
to provide technical support and respond to your requests

4.2. Personalization of your experience

to remember you next time you visit our Website

4.3. Prevention of fraud and illegal activity

to enforce our policies and Terms and Conditions

4.4. Compliance with our legal or regulatory obligations

to comply with the applicable laws (such as obtaining your consent, if you are in a consent jurisdiction -EEA or US-), including laws outside an end user’s country of residence
to comply with subpoenas, warrants, or other legal process
to respond to requests from public and government authorities including public and government authorities outside an end user’s country of residence
to enforce our terms and conditions
to protect our operations or those of any of our affiliates
to protect our rights, privacy, safety or property, and/or that of our affiliates, end users, or others
to allow us to pursue available remedies or limit the damages that we may sustain

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

5. On which legal basis do we process your Personal Data?

When we act as a data controller, we process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

Your consent: We process your Personal Data if you have provided your consent via a consent management platform available on our Website for a specific purpose. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.
Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are party, for example, in context of customer service.
Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations; for example, for tax and accounting purposes or legal disputes.
Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data via cookies to record your preferences related to cookies on our Website based on our legitimate interest related to be able to respect your rights.

Please see for additional information the section with service specific information below.

7. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfill the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services. This Policy does not apply to those parties, and Improve Digital is not responsible for their collection or use of information.

Vendors and service providers: We use a variety of vendors and service providers as part of, and for the purposes of, providing our Website. These could include cloud storage and cloud computing services. These vendors and service providers are subject to security and confidentiality restrictions to ensure their processing of the data is consistent with this policy.
External service providers: We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting and content delivery services, analytics services and video hosting services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
Affiliates and group companies: We share information with our affiliated companies, i.e. companies within our corporate family, which are also subject to this policy. We also share your personal data with our group companies. Where we share your personal data with our group companies, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared below.

8. Where will my Personal Data be processed?

In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

For further information on, or to receive a copy of, the adequate safeguards adopted by us for the international transfer of your Personal Data, please contact us by email at dpo@azerion.com. We will process any request in line with any local laws and our policies and procedures.

9. How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

10. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available above.

11. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

Access the Personal Data we hold about you, including information such as, for example, the source and categories of data, the processing purposes, the recipients (or categories thereof) and the respective retention period.
Request an update or correction of your Personal Data so that it is always accurate.
Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
Restrict the processing of your Personal Data for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for profiling. In that case, we will stop processing your Personal Data for such purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

12. How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support via our Website or our Data Protection Officer via e-mail to dpo@azerion.com.

13. How often do we update this Privacy Notice?

We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.

This Privacy Notice was last updated on 17 May 2023.

14. Additional Information for California Residents

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.

We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D – Commercial information (such as purchase history)
Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
Category G – Geolocation data
Category H – Audio, electronic, visual, thermal, olfactory, or similar information

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

15. Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

Service Specific Information

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting

Improve Digital is hosted by external companies to provide its Services to its clients. For example, every time you click on a link on our Website, the information allowing this request (e.g., device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Customer service

If you contact us for customer support by using our email address, we will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend against possible future legal claims. We process this data on the basis of performance of contract to provide you with customer support, and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.

Payments (billing and invoicing)

We process your billing and invoicing information in order to make you payments of your revenue share from our monetisation services. We process this data on the basis of performance of contract to provide you our Services.

Third Parties of Improve Digital

This list includes information about the third parties that your data may be shared with, in the way described in our Privacy Notice.

Under “Category”, you will find information about the activity your Personal Data is processed for, such as for customer service. The “Third party” indicates what third party specifically processes your data for the respective category. “Retention time” provides information about the amount of time your data is kept for. The information that is included in this column is based on the information we have received from the third parties. For the most up to date information about the retention times, we refer to the privacy notice of the respective third party, which we have included in this list. In the third-party privacy notices, you will furthermore find information on how they collect and process your personal data.

Category	Third party	Retention time	Privacy Notice
Hosting	Amazon Web Services (AWS)	2 weeks	https://aws.amazon.com/privacy/
Customer service	Zendesk, Inc.	40 Days	https://www.zendesk.co.uk/company/customers-partners/privacy-policy/

Improve Digital Cookie Notice

This cookie notice (“Cookie Notice”) applies to Azerion Technology B.V. (“Improve Digital”, “we”, “us” or “our”) website (“Website“). It explains what the used technologies are, why we use them and the duration of their use as well as your rights to control our use of them. For more information about the ways in which Improve Digital handles personal data, please refer to our Privacy Notice.

What are cookies and similar techniques?

Cookies are small pieces of information (small files) stored within your browser or on your device. There are similar techniques as cookies such as Flash cookies, web beacons, small graphic files (pixels) and an additional HTML5 (local) storage in your browser. These techniques function in a similar manner as cookies. Where we refer to ”cookies” in this Cookie Notice, we also mean similar techniques.

Cookie Parties

As Improve Digital, we place cookies when you visit our Services that are only readable for us (”1st Party Cookies”), as do the third parties (”3rd Party Cookies”). These cookies are only readable for the third party. Our list of 3rd party list provides an overview which third parties we work together with and where you can find the privacy notices of each third party.

Cookie Types

Cookies that are essential for the functionality of our Services (also known as “Strictly necessary” cookies):

Since these cookies are essential, they are always active in our Services. We respect your preferences and in order to make your choices valuable and effective, we keep strictly necessary cookies out of types of cookies that we ask for your consent. We use these cookies for activities such as recognising you when you sign-in to use our Services so that you do not have to log in manually the next time you visit www.improvedigital.com.

Cookies that help to a better user experience (also known as “Functional” cookies):

For example, we use these cookies to remember information when you fill in forms or input fields on various pages and to keep track of your preferences such as language settings, location settings, etc.

Cookies that assist us to maintain advertising activities (also known as “Targeting cookies”):

These cookies ensure that it is possible for us to display personalized ads, to track which ads you have already seen and to track how many visitors click on an advertisement. Please note that you will still be shown advertisements even if these cookies are not used as we also display ads that do not use cookies.

For more information regarding the cookies used by advertising networks, we refer you to terms and conditions, cookie policies and privacy policies applicable to these platforms as can be found on our 3rd party list.

Cookies that allow us to gather information about the way visitors use our Services (also known as “Performance” cookies):

The information we gather from these cookies is used to generate site statistics. These statistics provide us with insights, such as how often our Services are visited, which parts or features are mostly viewed, how often our Services are interacted with. We continuously try to measure which Services of us are the most popular that attracts most visitors and users. This allows us to make the structure, navigation, and content as user-friendly as possible.

Cookies on “improvedigital.com”

We use cookies on our improvedigital.com website on which you can find this Cookie Notice. You can find the detailed cookie information below.

Strictly Necessary Cookies

Host	Cookie Name	Purpose	Lifetime
improvedigital.com	OptanonAlertBoxClosed	This cookie is set by websites using certain versions of the cookie law compliance solution from OneTrust. It is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie has a one year lifespan and contains no personal information.	364 days
improvedigital.com	OptanonConsent	This cookie is set by the cookie compliance solution from OneTrust. It stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users browser, when consent is not given. The cookie has a normal lifespan of one year, so that returning visitors to the site will have their preferences remembered. It contains no information that can identify the site visitor.	364 days
Origin.improvedigital.com	PHPSESSID	PHP session cookie associated with embedded content from this domain.	Session
Origin.improvedigital.com	AWSALB	AWS ELB application load balancer	6 days
status.improvedigital.com	XSRF-TOKEN	This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks.	Session
status.improvedigital.com	laravel_session	Cookie used to identify a session instance for the user	Session
Origin.improvedigital.com	AWSALBCORS	This cookie is managed by AWS and is used for load balancing.	6 days

Performance Cookies

Host	Cookie Name	Purpose	Lifetime
improvedigital.com	_gat	This cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate – limiting the collection of data on high traffic sites. It expires after 10 minutes._ga	Session
improvedigital.com	_ga_S3NTV1GFB4	Used to identify unique users	729 days
improvedigital.com	_pk_ses*	This cookie name is associated with the Piwik open source web analytics platform. It is used to help website owners track visitor behaviour and measure site performance. It is a pattern type cookie, where the prefix _pk_ses is followed by a short series of numbers and letters, which is believed to be a reference code for the domain setting the cookie.	Session
improvedigital.com	_gid	This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited._gid	Session
improvedigital.com	_pk_id*	This cookie name is associated with the Piwik open source web analytics platform. It is used to help website owners track visitor behaviour and measure site performance. It is a pattern type cookie, where the prefix _pk_id is followed by a short series of numbers and letters, which is believed to be a reference code for the domain setting the cookie.	392 days
improvedigital.com	_ga	This cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners.	730 days
improvedigital.com	ln_or	Used to determine if Oribi analytics can be carried out on a specific domain.	Session

How can cookies be deleted?

If you do not want websites to place cookies on your devices, you can adjust the browser settings so that your browser refuses all cookies or only third-party cookies. You can also delete cookies that have already been placed. Note that you must adjust the settings separately for each browser and computer that you use. If you decide to disable all cookies, some parts of our Services may not function properly.

How you can adjust the settings differs per browser. If necessary, consult the help function of your browser, or click on one of the links below to go directly to the manual of that specific browser.

• Microsoft Edge

• Firefox

• Chrome

• Safari

If you want to disable cookies from specific parties, you can do so via:

• http://www.youronlinechoices.eu

• http://optout.networkadvertising.org

• http://optout.aboutads.info

Furthermore, you can withdraw the consent you gave for non-essential cookies at any time under the link “Cookie Settings” or you can exercise your right to withdraw your consent by contacting us as described in our Privacy Notice.

Updates to this Cookie Notice

We will amend this Cookie Notice when we implement new technologies and functions. If we make significant changes, we will notify you of this. For example, by posting a notification on our websites and/or apps, through email, pop-ups (e.g. by requesting your consent again), or similar methods.Questions or complaints regarding privacy or cookies can be sent to dpo@azerion.com.