1. Introduction and general terms
These terms apply to the websites and other products offered by ADZ VENTURES MEDIA INTERNATIONAL and its subsidiaries referring to this policy (“India”). Our registered office is at 426/2 Ground Floor Ghitorni New Delhi 110030. We are a company registered in the India, with company number 363564
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal information you have provided to us.
Our Website may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. Our online services
We operate an affiliate marketing network. This means we have established a network of online merchants who want to promote their products and services online, and we are able to connect them with a network of online publishers which are able to display advertisements for those products and services. Publishers may operate websites, apps or other (digital)services.
Our role is to help advertisers and publishers understand which advertisements displayed by publishers have generated which sales, leads or other actions for advertisers. This allows advertisers to pay a publisher only when the advertisement displayed (or any alternative required action) by the publisher refers an individual to the advertiser and that individual makes a purchase.
We use data, including cookies, to achieve this understanding. This data relates to individuals, but does not identify them by name. It relates to a single referral by an individual from one website to another, and then a confirmation that a purchase was made. We also maintain a database of references to individual’s devices, so that we can understand whether an advertisement viewed on one device, for example a phone, caused a purchase to be made by that individual on one of their other devices, for example a laptop. This database does not allow people to be identified by name.
We do not build profiles which show individuals internet usage over a period of time. We also do not target individuals with advertisements for products and services based on their perceived interests. Our role is simply to measure the effectiveness of specific online advertisements.
Therefore, if you click on an advertisement on one website, and then complete a transaction on the website to which you were referred, we may process your personal data so the publisher of the advertisement can be paid for displaying that advertisement.
If you would like to know more about our Services and how we comply with data laws, you can read our Whitepaper here.
We also operate our own website and we consider how users navigate that website so we can improve it, make it more useful and appealing, and remove bugs or other errors.
3. Information we may collect about you
When you use our Online Services we collect and process the following information which may include your personal data.
Information provided by you when using Partner Websites
We will maintain a record of your journey from one website to another for up to 365 days, and also a confirmation of whether you have completed a purchase from the second website as a result of that journey.
This takes the form of a cookie, and other information to allow us to identify your devices. This may be achieved by recording device IDs or by recognising combinations of device attributes.
Finally, advertisers will tell us information about what products and services you may have bought, but they do not provide information that could allow us to identify you.
Information collected for the purposes of providing analytics (“Analytics”)
We may collect technical information about your use of the Website through the use of tracking technologies and analytics. This information does not allow us to identify you.
4. Why we collect information about you
To provide our Services
We will use Partner Information to provide our Services to Partners, as described above. We also use Partner Information to prevent fraud.
We do this on the basis that it is in our legitimate interests to do so, having considered any consequent impact on your rights to privacy.
In some instances, advertisers ask us to collect other data from their website and relating to website users. We only do this on instruction from our advertisers.
To operate our Website
We will use Analytics for delivering our Website to you. This may include learning how individuals tend to use our Website, so we can make improvements. We do this on the basis that it is in our legitimate interests to do so, having considered any consequent impact on your rights to privacy.
5. Data sharing
Partners: We are engaged by Partners to provide Services to them. You may have submitted Partner Information to us as part of your use of any of our Partners websites or other online services. We will share that data with the Partner in accordance with any agreements we have entered with the Partner.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of TradeTracker.com, our customers, or others.
6. Your rights in relation to personal data which we process relating to you
You have the following rights over the way we process personal data relating to you, as set out below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let us know by sending an email to [email protected].
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
- you consented to our processing the personal data, and have withdrawn that consent;
- we no longer need to process that personal data for the reason it was collected;
- we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of TT or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed;
- you need the personal data to be deleted in order to comply with legal obligations;
Obtain a machine readable copy of your personal data, which you can use with another service provider
- If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
- If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
- If you seem this appropriate, you have the right to file a complaint with the Data Protection Authority.
7. Data retention
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as TradeTracker management or employees whose main role requires system access).
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
10. International data transfers
Our servers are located in India.
It is possible that your personal information may be transferred outside of the INR by any of our Partners. We recommend that you refer to their privacy policies and/or terms and conditions if you are concerned about your data being transferred outside the INR.
Where we transfer your information outside of the EU, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to [email protected]