Pokkt is committed to protect the privacy of the users who access its platform (the Platform). This privacy policy statement (the Privacy Policy) generally explains the types of information Pokkt gathers and what Pokkt does with it. By using or visiting the Platform, you agree to (i) the terms and policies described in this Privacy Policy; and (ii) to the collection of information described in this Privacy Policy.

This Privacy Policy addresses the Pokkt privacy and data protection practices and also outlines Pokkt’s business, how Pokkt works, and how Pokkt’s technology interacts with personal information from three sources:

  • Non-registered visitors to www.pokkt.com (Visitors).
  • Registered members of the Platform (Member(s)).
  • Web users who click on offers, banners or any other Pokkt offering (End Users).

  1. Collecting Personally Identifiable Information

    Pokkt collects from Members Personally Identifiable Information (as defined below). You acknowledge such collection of information is done on a voluntary basis to enable Pokkt to provide you efficient access to features, functions, promotions, products and services.

    Personally Identifiable Information means any information given by a Member to Pokkt or obtained through the use of the Platform which might reasonably be used to specifically identify you and may include, among other, your name, title, location, phone number, address or email.

  2. Non-Personal Information

    • Pokkt automatically collects from Members non-personal information such as IP addresses, the content and pages that you access on the Platform, and the dates and times that you visit the Platform, paths taken, and time spent on sites and pages during your access and use of the Platform.
    • Pokkt automatically collects from Visitors non-personal information such as IP addresses and other web information.
    • Pokkt automatically collects from End Users non-personal information such as IP addresses, a unique user ID, sites that s/he arrived from, impressions, clicks and the completion of offers/tasks.Impressions, clicks and the completion of offers/tasks are collected on an aggregated demographic base (per age, gender and country).

    Non-Personal Information means any information collected by Pokkt under sections 2(i) through 2(iii).Non-Personal Information is used, amongst others, to help diagnose problems with Pokkt’s server, to identify ways of making the Platform better, for security and monitoring purposes and to present the user with the most relevant offers and/or banners for him.

    Opting Out on Android Devices On a Android device to opt out of our behaviorally targeted advertising services, you may do this as follows:

  3. Use of Digital Identifiers

    Pokkt automatically uses Digital Identifiers (as defined below), amongst others, for tracking activities, identification, security and/or the user characteristics. No Personally Identifiable Information is collected by use of Digital Identifier. Pokkt uses the information collected through Digital Identifiers, amongst others, to analyze trends, administer the Platform, track movements on the Platform and gather aggregate demographic information about visitors so that Pokkt can continually improve the Platform. This Privacy Policy covers the use of Digital Identifiers by Pokkt and does not cover the use of Digital Identifiers by any third party (such as advertisers) who may be promoted through the Platform (Digital Identifiers will be used for all users of the Platform).

    Cookies means information that a website puts on your hard disk so that it can remember something about you at a later time (more technically, it is information for future use that is stored by the server on the client side of a client/server communication).

    Web Beacons means a transparent GIF image that enables Pokkt to count page views and to retrieve information from the Cookies Pokkt saved on your computer.

    Digital Identifier means Cookies or Web Beacons.

  4. Security

    Pokkt employs industry standard security measures to ensure the security of data it collects. Any data that is stored on Pokkt’s servers is treated as proprietary and confidential. Pokkt maintains an internal security policy with respect to the confidentiality of your data.

    While Pokkt has taken measures to protect information it collected, please know that (i) no computer system is immune from intrusion; and (ii) information transmitted to the Platform may need to pass through many systems in order to process such information. Therefore, Pokkt cannot guarantee the absolute security or confidentiality of information transmitted to the Platform and you hereby acknowledge and assume the risks relating to any such communication.

  5. Information Sharing

    Pokkt may use the collected Personally Identifiable Information and Non-Personal Information (together Information) for any legally permissible purpose in its sole discretion, including, but not limited to, the following:

    • Sharing Information with affiliated companies. This Privacy Policy does not apply to affiliated companies and their collection, use and sharing of information.
    • Sharing Information with various third party vendors that are not part of Pokkt (or its affiliates).
    • Using third party service providers to enhance the Platform with additional elements of Pokkt’s services.

  6. Third Party Links

    The Platform may offer links to other websites. Other websites have their own terms of use and privacy and security policies. If you choose to visit one of these websites, you should review the policies that govern that particular website.

  7. Permitted Disclosures

    Other than as described in this Privacy Policy or as otherwise specifically communicated to you by Pokkt, Pokkt will not provide Information to any third parties, except where law, court order, or governmental authority requires or based upon the good faith belief that disclosure is necessary including, without limitation, to protect the rights of Pokkt when we have reason to believe that disclosing the Information is necessary to identify, contact or bring legal action against someone who may be causing interference with Pokkt’s rights or causing harm to third parties.

  8. Revision

    Pokkt may alter, update or otherwise change this Privacy Policy at any time. Any such changes will be posted on this page. You should periodically check this Privacy Policy to review the current terms and guidelines. Your continued use of the Platform following the posting of such changes will indicate your full acceptance of those changes.

  9. Pokkt’s Commitment to Children’s Privacy

    IF YOU ARE UNDER 18 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE PLATFORM AT ANY TIME OR IN ANY MANNER.

    Pokkt does not knowingly collect or maintain Personally Identifiable Information from persons under 18 years-of-age. If Pokkt learns that Personally Identifiable Information of persons less than 18-years-of-age has been collected on or through the Platform, then Pokkt will take reasonable steps to delete this information.

    If you are the parent or legal guardian of a child under 18 who uses the Platform, then please contact Pokkt at contact@pokkt.com to have that child’s Information deleted.

  10. Your choices and opting-out

    We undderstand the importance of your online privacy , so we offer the following options for controlling the targeted ads you receive and how we use your data:

    Opting Out on iOS Devices

    On a Apple device, you can opt out of our behaviorally targeted advertising services, you may do this as follows:

    • Clicking on Settings -> General -> About -> Advertising.
    • Toggling Limit Ad Tracking to ‘ON’.

    Our systems are designed to respect your choice and not use information to provide interest-based advertising when this setting is ON. Again, you should consult Apple’s support web pages and instructions for the most current applicable settings.

    Opting Out on Android Devices

    On a Android device to opt out of our behaviorally targeted advertising services, you may do this as follows:

    • Open the Google Settings app on your device
    • Select Ads
    • Either “Reset advertising ID” or
    • Opt out of interest-based ads

    Our systems are likewise designed to respect these choices transmitted by your Android device. Again, however, please consult Google’s settings and instructions for the most current settings information.

  11. Updating Your Personal Information

    Members can access and correct their Information and privacy preferences by accessing their Account details page in the My Account menu in the Platform, or by sending an e-mail to contact@pokkt.com. To the extent permissible under the applicable law, Members may occasionally receive e-mail messages from Pokkt

  12. The EU General Data Protection Regulation (GDPR)

    As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (the “GDPR”) will be in effect through the EEA, Switzerland, and the UK. This requires Pokkt and those using our services to provide users with certain information about the processing of their “Personal Data”.

    “Personal Data” is a term used under the GDPR that means, generally, data that identifies a particular unique user or device – for instance, names, addresses, cookie identifiers, Mobile IDs, precise location data, and biometric data.

    To comply with the GDPR, we provide the following information, which are specific to users located in the EEA, Switzerland, or the UK.

    1. Legal Grounds for Lawful Processing of Personal Data

      The GDPR requires us to tell you about the legal ground we are relying on to process any Personal Data about you. Typical legal grounds for us processing your Personal Data are:

      • You have given your consent. In order to store and gain access to information stored on your device, we rely on your consent. For this “cookie consent” (which applies not only to “cookies” but also to Mobile IDs), we rely on publishers and oblige them contractually to pass on only legally obtained data. We do so to fulfil our obligations under the ePrivacy Directive. We might ask for consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal.
      • The processing is in our legitimate scope. In few scenarios, we rely on legitimate interest as a legal basis for processing Personal Data, in order to provide our and/or other data controllers’ services. Such processing goes beyond the original collection of Mobile Identifiers. A valid use case is the customising of promotional communications within mobile applications and services, which is beneficial to End Users and is an integral part of the ecosystem by which freely available content is funded through advertising revenue. This also may include providing analysis of and reporting about ad campaigns.
      • Contractual relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information).
      • Legal obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

    2. Transfers of Personal Data

      As Pokkt works with global companies, we may need to transfer your Personal Data outside of the country from which it was originally provided.

      When we transfer Personal Data outside of the EEA, Switzerland, or the UK, we take steps to ensure appropriate safeguards are in place to protect your Personal Data. Please contact us for more information about the checks we have put in place to protect your Personal Data.

    3. Personal Data Retention

      We retain your Personal Data for as long as necessary to provide our Pokkt Ad Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally render Mobile IDs inactive within 24 months, provided that we may retain them if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance accounting, or bug-fixes.

      If you are a Client of ours and thus have an account with us, we will typically retain your Personal Data for a period of 3 years after you have requested that your account be closed, or such account has been inactive.

    4. Your Rights as a Data Subject

      The GDPR provides you with certain rights in respect to Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).

      • Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the e-mail address contact@pokkt.com. When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. We will then assess requests to exercise data access rights on a case-by-case basis; in doing so, we consider the difficulty of verifying whether a mobile identifier and data we have linked to it truly and solely belongs to the data subject making the request, as well as the potential adverse effects on disclosure of personal data to the wrong individual.
      • Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
      • Right to Object to Processing or to Withdraw Consent: We rely on device-based “opt-out” for your consent. If you opt out, we will stop processing your Personal Data for purposes of our services within 30 days or less.
      • Right to Delete. You also have the right to get your Personal Data removed concerning you that we hold as a data controller. When an User opts-out through device settings, and we receive this inform from our publishers, the Personal Data we use to provide our services will be deleted within 30 days (For an Android device) or permanently rendered disconnected to your device (For an iOS device). We will also manually delete your Personal Data, subject our identity verification process mentioned above, if you prefer that we do so; please contact us contact@pokkt.com for further instructions on exercising this right manually. We might, retain copies of certain Personal Data on inactive or back-up files for purposes like auditing, accounting and billing, legal, bug detection.
      • Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we sincerely hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.

    5. Pokkt as a Data Controller and a Data Processor

      EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”).

      Pokkt may act as either a data controller or a data processor in handling your Personal Data, depending on the precise circumstances. For instance, for Personal Data that we collect and use for self purpose to create our own tools and operate the Pokkt Ad System, we are a data controller.

      When we handle Personal Data strictly on behalf of our Clients or Partners in order to provide our services to them, we are a data processor. For example if you have queries about data that is used primarily by a mobile app in which our SDK is integrated – or companies that serve ads that use our technology – you should contact those companies regarding questions about the Personal Data they handle and control.

  13. Contact Us

    If you have questions about this Privacy Policy, please send an e-mail to contact@pokkt.com. If you believe that Pokkt has not complied with this Privacy Policy with respect to your Information or you have other related inquiries or concerns, you may write to Pokkt at the following address or e-mail: contact@pokkt.com.

    YOU ACKNOWLEDGE AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, AS WELL AS, IF APPLICABLE, THE GENERAL TERMS AND CONDITIONS BETWEEN YOU AND POKKT AND THE PLATFORM (INCLUDING LIMITATIONS ON DAMAGES).

Last Update: June 2018
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