Information about who we are
PURPOSE OF THIS POLICY: This Policy aims to give you information on how Tremor International collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our website or purchase products or services from us.
It is important that you read this Policy together with any other policy or notice we may provide so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
CONTACT DETAILS: Our full details are:
- Full name of legal entity: Tremor International Ltd.
- Email address:
- Postal address: 121 Hashmonaim Tel Aviv, 6713328 Israel
- Telephone number: 972-3-545-3900
CONTROLLER: Tremor International Ltd. is made up of different legal entities. This Policy is issued on behalf of the Tremor International Group so when we mention “Tremor”, “we”, “us” or “our” in this Policy, we are referring to the relevant company in the Tremor International Group responsible for processing your data.
If you have any concerns about how we are handling your data you have the right to make a complaint to your data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
CHANGES TO THE POLICY AND YOUR DUTY TO INFORM US OF CHANGES: This version was last updated on June, 2019. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS: This website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Please note this website is not intended for children and we do not knowingly collect data relating to children.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. We have categorised these as follows:
- Identity includes first name, last name, username and title.
- Contact includes billing and delivery address, email address and contact numbers.
- Financial includes bank account and payment details.
- Transaction includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage includes information about how you use our website, products and services.
- Marketing and Communications includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. This data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you do not provide that data, we may not be able to perform the contract (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect data from and about you as follows:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone or email. This includes personal data you provide when you: (a) apply for our products or services; (b) create an account on our website; (c) subscribe to our service or publications; (d) request marketing to be sent to you; or (e) give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies.
HOW WE USE YOUR PERSONAL DATA
We only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than when we send third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at .
Purposes for which we will use your personal data
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer Identity; Contact Performance of a contract with you To process and deliver your order including managing payments, fees and charges and collecting and recovering money owed to us Identity; Contact; Financial; Transaction; Marketing and Communications Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and this website (including troubleshooting, data analysis, system maintenance, support, reporting and hosting of data) Identity; Contact; Technical Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
Necessary to comply with a legal obligation
To deliver relevant website content Identity; Contact; Usage; Marketing and Communications; Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical; Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
- Marketing. We want to ensure that you have choices regarding certain personal data uses, particularly around marketing and advertising. Please contact us if you want to change your marketing preferences.
- Third-Party Marketing. We will get your express opt-in consent before we share your personal data with any company outside the Tremor International Group of companies for marketing purposes.
- Opting out. You can ask us to stop sending you marketing messages at any time by contacting us at . Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
- Change of Purpose. We will only use your personal data for the purposes for which we collected it, unless we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact . If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
- Internal Third Parties: other companies in the Tremor International Group acting as joint controllers or processors.
- External Third Parties including:
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide services to us.
- Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit our service providers to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Tremor International Group. This will involve transferring your data outside the European Economic Area (EEA). In addition many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data.
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
- Right to withdraw consent where we are relying on consent to process your personal data.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Last Update: June 2019