Privacy Rights Policy
Subject to applicable law requirements, Apester Ltd and its affiliated companies and subsidiaries (collectively “Company” or “we” or “us”) provides individuals with the opportunity to exercise their rights regarding their Personal Data.
We value the privacy rights of our Business Partners, website’s Visitors and Users (as defined in our Privacy Policy, and collectively “you” or “yours”). Thus, we have designed this Privacy Rights Policy (“Privacy Rights Policy” or “Policy”) as an overview of your rights regarding your Personal Data, under applicable laws, including the EU General Data Protection Regulation (“GDPR”); and the California Consumer Privacy Act of 2018 (“CCPA” or “Act”) which shall apply to you in the event you are a “California Resident”, as defined under the CCPA.
Please note that, you may have different rights then those which we listed below, subject to privacy protections laws in your jurisdiction. In addition, please be advised that with regards to certain Users Personal Data, Apester acts as a processor on behalf of Business Partners, and thus, any request to exercise rights with regards to such data should be addressed to those Business Partners (for example, the operator of the websites in which the Content Unit you interacted with was implemented).
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have a right to request us to confirm whether we process certain Personal Data related you, as well as a right to obtain a copy of such Personal Data, with additional information regarding how and why we use this Personal Data. The GDPR and CCPA provide different protections, the GDPR enables access to all Personal Data processed by the controller, however the CCPA “Access Right” applies only to Personal Information collected in the 12 months prior to the request. After we receive such request, we will analyze and determine the veracity and appropriateness of the access request and provide you with the applicable confirmation of processing, the copy of the Personal Data or a description of the Personal Data and categories of data processed, the purpose for which such data is being held and processed, and details about the source of the Personal Data that was not provided by you.
DELETION REQUEST RIGHTS
The Company is legally obligated to comply with a request to delete Personal Data processed by it as a controller, if:
- the data is no longer needed for the original purpose and no new lawful purpose exists for continued processing;
- the lawful basis for processing is consent of the data subject and such consent is withdrawn;
- the data subject exercises his or her right to object to the Company’s processing of his or her Personal Data, and the Company has no overriding grounds for processing the data;
- the Personal Data is processed unlawfully;
- erasure of the Personal Data is necessary to comply with applicable laws.
- if the Company has passed on Personal Data to a third party, a data subject also has a right to oblige the Company to tell those third parties that the information should be erased.
The right to erasure is not absolute. Even if a data subject falls into one of the categories described above, the Company is entitled to reject the data subject’s request and continue processing data subject to applicable law, for example, if such processing is: necessary to comply with legal obligations; necessary to establish, exercise or defend legal claims; necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity, etc.;
RIGHT TO OBJECT/RIGHT TO OPT OUT
Under the lawful basis of our legitimate interests and with regards to Personal Data processed by us (such as direct marketing), you may object to our processing on such grounds.
YOUR RIGHT TO BE INFORMED
You have the right to be informed with the Company’s details (e.g., name, address, etc.), as well as why and how we process Personal Data. We provide with such information under our Privacy Policy.
THE RIGHT OF RECTIFICATION
You have the right to require us to update Personal Data that is inaccurate.
THE RIGHT OF RESTRICTION
You may limit the purposes for which the Company may process your Personal Data in the event that, for example, the accuracy of the data is contested; processing is unlawful, etc.
NONDISCRIMINATION
Under the CCPA, you must not be discriminated for exercising any of your rights, including by denied goods or services, charging you with different fees for goods or services, including through the use of discounts or other benefits or imposing penalties; suggested you will receive a different price or rate for goods or services.
We endeavor to respond to a verifiable consumer request with undue delay and in any event according to the time frames determined under applicable laws. If we require more time, we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Further, note, under the CCPA your rights only apply to the Personal Information collected 12 months prior to the request and you are not entitled to submit more than 2 requests in a 12 months period.
This Policy applies solely to your rights concerning Personal Data processed by us.
If you wish to exercise your rights, please submit a request by filling out the Privacy Rights Request form, and send it to our privacy team at: privacy@apester.com.
