Privacy Policy

We believe that Your privacy is extremely important. Please read this document carefully as it contains the Privacy Policy (“Policy”) of the website www.pubgalaxy.com (“Site”) and the Services provided to You in accordance with the respective individual Services Cooperation Agreement (“Agreement”) which, all together, are referred to as the “Services”. Please note that this Policy may be amended from time to time and that any changes will be published here.

PUBGALAXY PRIVACY POLICY

PubGalaxy, and its associated properties (www.pubgalaxy.com), is owned/operated and controlled by Titan Gate AD (“PUBGALAXY”/”we”/”us”), with registered address: Administrativna sgrada Pivovaren zavod, floor 3, Zapadna promishlena zona, 9000 Varna, Bulgaria, UIC: 204039974.

By using the Services or submitting Personal Information through our Services, you acknowledge and agree to the terms of this Policy and to the processing of your Personal Information in accordance with this Policy.

Upon processing of personal data, PUBGALAXY complies with all applicable data protection legislative acts, including, but not limited to Regulation (EU) 2016/679 (the “Regulation”).

Personal data, in accordance with the Regulation, means any information relating to You which makes You identifiable (such as your name, postal address, e-mail address or telephone number, and information about your use of our services).

Personal data processing (“Processing”) means any operation or set of operations which is performed on personal data by automated or other means.

Please note that this Policy does not to apply to personal data You may provide to, or which is being processed by third-parties, who are not affiliated with PUBGALAXY or do not process personal data on behalf of PUBGALAXY. These third-parties are Demand Partners and Advertisers, Ad-Networks and Ad-Servers and other parties purchasing Ad Inventory or placing Ads on Your media in accordance with the Services or any other non-affiliated third-party. In these cases, the privacy policies of these third-parties shall apply to that online service and we encourage You to get familiar with their privacy policies to learn more about their privacy practices. For more information please refer to the Section 8 “Important information for You about data processing activities when using third-party technology for the provision of the Services” below.

Contents

1. Who are the Data Subjects whose personal data is processed by us?

In connection with the provision of the Services, PUBGALAXY processes information regarding the following Data Subjects:

  1. Clients who have entered into Agreement with PUBGALAXY (“Clients”) and/or their employees and/or agents (“Representatives”);

  2. Potential clients and/or their Representatives;

  3. Persons and/or their Representatives who have subscribed to receive our newsletter;

  4. Former clients and/or their Representatives;

  5. Visitors of the Site.

2. What information does PUBGALAXY process about its potential clients?

In order to establish business relationship with potential clients, and to offer our Services to potential ones, we may use certain tools to check the website traffic, statistics and rankings of Your website (e.g. to perform a website vetting). In such cases, PUBGALAXY uses only publicly available statistical information and does not process any personal data related to You and/or to Your Representatives.

2.1. Information we may identify about You

If a website passes our vetting criteria, we may attempt to: (i) identify the publicly available contact details, related to you; (ii) establish business relationships with You in order to provide our Services. In such cases we may process the following publicly available information about You:

  • Name;

  • Website (URL);

  • Business contact details (address, phone number, email address etc.);

  • Information about public business profiles in social networks, including pictures (LinkedIn Profile; LinkedIn Page; Facebook Page of Your company; Twitter business account).

2.2. Information provided by You

You may also decide to contact us in order establish a business relationship with us and/or to receive our Services. In such cases you may want to contact us either via the publicly available contact details of PUBGALAXY or via the contact form on our Site. Within the forms for entry of personal data, we clearly indicate, whether the data is mandatory or voluntary. Mandatory data is considered such data, without which We would be unable to process Your request. In cases you contact us, we may process the following information related to You:

  • Name;

  • Website (URL);

  • Your organization or the organization You are working for;

  • Information about how You heard about us;

  • Business contact details (address, phone number, email address etc.);

  • Information about public business profiles in social networks, including pictures (LinkedIn Profile; LinkedIn Page; Facebook Page of your company; Twitter business account);

  • Information created or provided by You about Your current monetization practices related to Your website, such as: (i) usernames and passwords You provide us with, in order to grant us access to the monetization panels you’re using; (ii) information about revenues and incomes of Your website etc.;

  • Other information You provide in Your request or in the following communication and negotiations with us;

PUBGALAXY will treat the provided information with strict confidentiality and in compliance with this Policy and all applicable data protection legislative acts, including, but not limited to, the Regulation.

3. What information does PUBGALAXY process in connection with the provision of the Services to You?

If You are a Client of PUBGALAXY, we may process the following information about You:

3.1. Information provided by You

Registration and use of a client account.

Only persons or companies, which have entered into an Agreement with PUBGALAXY (Client) are entitled to register and use a client account on the Site. To register and use a client account on the Site, information regarding the Client and/or the Client Representatives and/or contact persons is required. This information may include, but is not limited to: names, address, date of birth, telephone number, email address, position (capacity) of the Representatives/ contact persons, company contact information, company name, Commercial Register Number or other tax or registration number relevant for the invoicing and taxation.

Newsletter, marketing materials or participating in our surveys.

Upon registering for the Service, each person or their representative/Company is automatically subscribed to receive: (i) our newsletter, (ii) our marketing materials and (iii) our surveys, as noted in our Agreement - unless the Client has requested for the respective clauses to be removed. For carrying out these purposes, PUBGALAXY may process your name, email address, company name, online location identifiers, profile picture and the method of reaching the page for subscription (in case the person is not a PUBGALAXY Client). The Client may unsubscribe from receiving (i) our newsletter, (ii) our marketing materials and (iii) our surveys an any time.

When You unsubscribe from the: (i) newsletter; (ii) marketing materials; (iii)surveys, PUBGALAXY may process information related to the reason for unsubscribing.

Special categories of data (sensitive data)

The Services provided by PUBGALAXY and the functionalities available on the Site are not intended for collection, storage and processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation; or personal data relating to criminal convictions and offences (Special categories of data within the meaning of Art. 9 and Art. 10 of the Regulation). PUBGALAXY does not and will not request from You the provision of any Special categories of personal data. You are kindly requested to never share with PUBGALAXY such type of information via the available electronic forms on the Site.

Other data

PUBGALAXY may as well process other data related to You, in cases where You voluntarily provide such data by filling in the respective electronic forms on the Site, adding preferences, settings, or allowing us to access Your website preferences and tools etc.

3.2. Data related to the process of use of the Services

In order to provide You with our Services we may process the following information about You:

  • Names, address, date of birth, telephone number, email address, position (capacity) of the Representative;

  • Company contact information, company name, Commercial Register Number or other tax or registration number relevant for invoicing or taxation;

  • Signature or data accompanying the electronic signature;

  • Information about websites under Your control;

  • Information about Your current monetization practices related to Your website, such as: (i) usernames and passwords You provide us with, in order to grant us access to the monetization panels you’re using; (ii) information about revenues and incomes of Your website etc.;

  • Information regarding the effected and due payments for Services (this information may include name, bank, bank account, VAT number, etc.);

  • Information related to the administration and provision of Services;

  • Information included in support tickets (incl. the status of a support ticket) and in internal reports;

  • History and information of ordered Services;

  • History and information regarding the use of Services;

  • Other information generated or provided during the use of the Services.

4. Whether and how we use Cookies on our Site?

Please note that this section does not apply to the use of cookies or other tracking technologies on the devices of Your website visitors and clients. For more information please refer to the Section 8 “Important information for You about data processing activities when using third-party technology for the provision of the Services” below.

The normal functioning of our Site requires the use of cookies. You can find a detailed description of the used cookies below.

Cookies allow information to be stored in your browser (or mobile application). They are used to store settings and identifiers required for the provision of the Services.

Cookies are used for the following purposes:

Type of Cookie

Storage period

Description

Session and navigation management (session identifier, security protection etc.)

Temporarily (for the duration of your visit on the Website)

These cookies are technically required to login, navigate and use the Website. TheWebsite cannot function properly and reliably without them.

Settings within the Website

Up to 3 /three/ months from the last use

These cookies are used to save your settings; allowing you to hide information boxes you have become familiar with, etc.

Automatic log in to Your account

Up to 3 / six / months from last use

In case you use this option, it allows you to automatically log in to your account. Please do not use this option, if you are not the only person who have access to Your device (PC, laptop, etc.)

Google Analytics & Interest-Based Online Advertising

Up to 26 months

This website uses Google Analytics. Google Analytics uses “cookies” to help us analyze how visitors use the site. The information collected includes the pages a visitor visits, the time a visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google will use this information on behalf of PUBGALAXY to evaluate your use of the website, compiling reports on website activity.

We also use Google Analytics' 3 rd -party audience data, such as age, gender and interests to better understand the behavior of our customers and provide advertising targeted to suit your preferences and interests. For example, you may see ads on the Google Display Network, based on information collected through automated means (such as cookies). Automated technologies are used to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts. You can set preferences for how Google advertises to you using the Google Ad Preferences Page and if you want you can opt out of interest-based advertising entirely by cookie settings or by using this Google tool .

Google AdWords Remarketing

Up to 18 months

This website uses AdWords Remarketing service to advertise to third party websites (including Google) to previous visitors of our website. This could be in the form of an advertisement on a Google search results page, or a site in the Google Display Network. Third party vendors (including Google), use cookies to serve ads based on someone's last visit to the PUBGALAXY website. Any data collected will be used in accordance with this Policy and Google's privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences Page , and if you want you can opt out of interest-based advertising entirely by cookie settings or by using this Google tool .

Facebook Pixel

Up to 28 days

Our website utilizes the Facebook Pixel, which allows us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy . You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation.

LinkedIn Insights Tag

Up to 6 months

The LinkedIn Insight Tag is a piece of lightweight JavaScript code that we have added to our websites to enable in-depth campaign reporting and to help us unlock valuable insights about our website visitors. We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about members interacting with our LinkedIn adverts. All data is encrypted. The LinkedIn browser cookie is stored in a visitor's browser until they delete the cookie, or the cookie expires. You can opt out of cookies from LinkedIn on your LinkedIn settings page .

Visitor-query cookie

30 days

To help us track the efficiency of our marketing efforts, we record data about the search term (keyword), if any, which led the user to the website. Information on the keyword is taken from the ad campaigns URLs, usually set through Google AdWords.

MailChimp Cookies

The contact form and the newsletter subscription form on our website are set through MailChimp and use automation to place single pixel gifs, also known as web beacons, in every email sent through MailChimp. These beacons are tiny graphic files that contain unique identifiers that enable us to recognize when the user has opened an email or clicked certain links. These cookies/beacons record each subscribers email address, IP address, date, and time associated with each open and click for a campaign. The data is kept on MailChimp servers in the US and MailChimp is part of the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation.


Control of cookies in the browser

If you want, you can also use your browser settings to delete and/or disable cookies from specific or all websites. More information about this can be found on aboutcookies.org.

Please note that by deleting any or all cookies, you may not be able to use the Site and/or the Services in their full or normal functionality.

5. For what purposes do we process Your personal data?

PUBGALAXY collects, uses, and processes the information described herein for the purposes provided for in this Policy. These include:

  • Purposes necessary for the conclusion and performance of the Agreement between You and PUBGALAXY:

    • Conclusion and performance of the Agreement;

    • Provision of Services, including the required data-processing upon registration, creating an account; and other activities related to the provision of the Services;

    • Customer support (processing of inquiries and support tickets; preparation of internal reports; communication with You, including by email, necessary for the provision of the Services and/or for notifying You of changes in the Services;)

    • Provision of information about the Agreement to our Demand Partners as negotiated in the Agreement and as far as it is our contractual obligation to the certain Demand Partners. The disclosed data may include name, signature, address, and website of a Client.

    • Placing ad-tags on Your website;

    • Consulting related to yield optimization and revenue analysis.

For these purposes, processing of some or all of the above-mentioned data categories might be necessary.

  • Purposes necessary for undertaking steps to conclude a contract at the request of the Data Subject, including processing of inquiries.

We may process the personal data provided by You on the basis of this legal ground, when you decide to contact us, in order to establish a business relationship with PUBGALAXY and/or to use our Services.

These purposes require only the processing of data, as described in section 2.

  • Purposes necessary for protecting and exercising the legitimate interests of PUBGALAXY and third parties:

  • Ensuring the Site’s normal operation and use by You; maintenance and administration of the Services;

  • Dispute resolution, detection and prevention of malicious activities;

  • Detection and repair of technical or functionality related issues;

  • Business planning;

  • Communication with You, including by email, on important issues related to the Services;

  • Contacting potential clients through their business contact details in order to establish business relationships with them; website vetting; analysis of current monetization of a website, and direct marketing;

  • Exercise and protection of PUBGALAXY’s rights and legal interests, including by legal proceedings, and rendering assistance to other users of the Site or the Services and/or affected third persons in exercising and protecting their rights and legal interests; establishment, exercise or defense of legal claims.

For these purposes, processing of some or all the above categories of data might be necessary.

  • Fulfilment of PUBGALAXY’s legal obligations.

These are purposes such as:

  • Financial and accounting activities where processing and storage of information is required by law for fulfilment of tax, accounting and other reporting obligations;

  • Activities related to the performance of statutory obligations for the retention or provision of information upon receipt of a relevant order issued by competent state or court authorities; to facilitate the competent state authorities in exercising their control powers;

  • Activities related to the performance of our legal obligations to notify You of various circumstances related to your rights, the Services provided or your data protection, etc.;

  • Documenting and reporting activities, and other obligations related to the fulfilment of the requirements under the Regulation and other applicable legislation.

For these purposes, processing of some or all the above categories of data might be necessary.

  • Purposes for which You have granted explicit consent.

In cases when we need data regarding the purposes listed below, your data shall be used only if explicit consent has been provided by You and the processing is specific, to the extent and within the scope provided for in the respective consent (e.g. when providing us with Your consent to distribute audio-video materials featuring Clients). These purposes may include:

  • Provision of information about current trends in the industry, presentation of new products and/or services, promoting successful projects and services, marketing activities, marketing studies, attracting new clients, etc.;

6. How long do we store information about You?

PUBGALAXY always applies the principle for storing data in minimal volume and for a period not longer than necessary for the purposes for which they were collected, ensuring that they are stored securely and in compliance with the applicable legislation.

We store the enlisted types of data for the following period:

Type of data

Storage period

Customer data related to the registration, agreement, declarations, etc.

For the duration of the agreement and for up to 5 /five/ years from termination of the agreement.

Invoices and other financial information

For the duration of the agreement and up to 5 /five/ years from termination of the agreement or up to 10 /ten/ years as of the beginning of the year following the one in which payment is due for the respective year

Cookies

Description and the storage period for the used cookies is available in Section 4 above.

7. Do we share information about You with third parties?

PUBGALAXY will not provide Your personal data to third parties in any way other than those set out in this Policy and the Services.

In fulfilment of its contractual obligations and as negotiated in our Agreement with the Client, PUBGALAXY may provide its Demand Partners with information about the Agreement concluded between PUBGALAXY and the Client. The disclosed data may include name, signature, address, and website of a Client.

In fulfilment of its obligations for provision of the Services, PUBGALAXY may also create accounts for You (on Your behalf) in advertising systems or platforms controlled by third parties and provide information to third parties with whom PUBGALAXY has business relationships. The disclosed data may include name, address, email address, and telephone number of a Client and/or its Representatives and/or contact persons. The use of personal data by such parties is governed by the privacy policies of such parties and is not subject to Our control.

PUBGALAXY works with subcontractors and service providers such as dedicated data centers for reliable and secure colocation of servers and network equipment, accounting services, etc. When working with subcontractors and suppliers, PUBGALAXY requires that they comply strictly with its instructions, this Policy.

8. Important information for You about data processing activities when using third-party technology for the provision of the Services

PUBGALAXY works with third-party partners in order to provide You with the Services. These third-parties are Demand Partners and Advertisers, Ad-Networks and Ad-Servers and other parties purchasing Ad Inventory or placing Ads on Your media in accordance with the Services or any other non-affiliated third-party (“Partners”).

On Your behalf in accordance with the Services we may place ad-tags on Your Website or/and to provide you with ad-tags for You to place on Your Website, in order to enable the Partners to collect web viewing data, place cookies or other tracking technologies on the devices of Your website visitors to inform, optimize, and serve personalized ads based on past website visits and to monitor ad impressions and other information in accordance with the Services. These Partners use technologies for automatic collection of information about the use of Your websites and the views of their ads. This information is directly collected by these Partners.

PLEASE NOTE THAT PUBGALAXY DOES NOT COLLECT, STORE OR PROCESS ANYHOW INFORMATION WHICH IS COLLECTED BY THE USE OF COOKIES OR OTHER TRACKING TECHNOLOGIES THAT MAY BE PLACED ON THE DEVICES OF YOUR WEBSITE VISITORS BY PARTNERS. PUBGALAXY NEITHER HAS ACCESS TO, NOR DOES THIS POLICY GOVERN THE DATA PROCESSING ACTIIVY PERFORMED BY PARTNERS.

It is Your obligation in accordance with the provision of the Services and the Agreement to ensure that You will inform Your website visitors and clients about the processing of their personal data by Partners in a way that your website has (a) a privacy policy that (i) discloses usage of third-party technology to collect and use data in connection with the Service, (ii) complies with all applicable privacy and data protection laws, and if data is collected for interest-based advertising purposes (b) a mechanism to obtain with respect to the Services, users’ prior and informed consent to the use of third-party technology (reasonable evidence of which shall be maintained to the extent so required), if required by applicable law.

It is Your obligation to inform Your website visitors about the:

  • The types of personal data processed through placed cookies or other tracking technologies by the Partners;

  • The purposes for which the personal data are collected and processed by the Partners;

  • The recipients/ categories of recipients of the collected personal data – to whom the collected data could be provided/ disclosed;

  • The period for which the collected data will be stored – retention periods;

  • Whether the data will be transferred to/ disclosed to persons outside the EU/EEA and if so, what kind of safeguards will be applied (e. g. adequacy decision of the European Commission; standard contractual clauses; EU-US Privacy Shield, etc.)

  • Information that the consent of the website visitors can be withdrawn at any time and how this right could be exercised;

  • The mechanism for obtaining and withdrawing the consent of data subjects for the processing their data by the Partners ( Note: The consent must be explicit and active (an “accept/understood – and decline/refuse button” is needed ). The settings of the data subjects’ browsers cannot be considered a valid consent for the use of cookies.)

All our Partners who place third-party technology on Your website have published in their privacy policies information about what personal data are being collected, stored or otherwise processed by them to optimize and serve personalized ads and to monitor ad impressions and other information in accordance with the Services. We are committed to providing you with all the assistance for You to comply with your obligations to inform Your website visitors about the processing of their personal data by the use of cookies or other tracking technologies that may be placed on the devices of Your website visitors. Therefore, we have compiled an exhaustive list of Partner who we work with, and who will process personal data by the use of cookies or other tracking technologies on Your website. We have also included links to their Privacy policies.

PubGalaxy works directly with the following Partners:

In the privacy policies of our Partners, they offer Your website visitors a way to opt-out of ad targeting as described above. We encourage You to include the above links to the privacy policies of our Partners in Your own privacy policy, in order to inform Your website visitors about what personal data are being collected, stored or otherwise processed by Partners and to provide them with an opportunity to opt-out of ad targeting.

Your website visitors can also check the Digital Advertising Alliance’s Opt-Out link for Consumers to use a single tool for opt-out of ad targeting. We encourage You to include this link in Your Privacy Policy as well.

Third party advertising companies

Additional third-party advertising companies, who may be indirectly involved in ad space monetization, may also be utilized through the direct Partners specified above. For these Partners, we put additional restrictions on how Your data can be stored and/or processed, to prevent misuse. You can choose to review this, as well as opt-out, by following the links in the list below:


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See the full list here

9. What rights do You have regarding the processing of personal data?

Regarding the processing of Your personal data for the purposes described in the Policy, you have the following rights:

9.1. Right of information. This Policy aims to inform You in detail about the processing of your personal data by PUBGALAXY.

9.2. Right of access. You are entitled to receive confirmation whether your personal data is being processed, to receive access to it, as well as information about processing and your rights.

9.3. Right of rectification. You are entitled to have your data rectified in case it is incomplete or inaccurate. Your data may be rectified by us upon Your request.

9.4. Right of erasure. You have the right to ask for data to be erased unless there is a material basis and/or legal obligation for their processing. However, please keep in mind that, certain data is required for proper provision of the Service.

9.5. Right of restriction of the processing. The Regulation provides for the possibility of restricting Your personal data processing in case there are grounds for this set forth therein.

9.6. The right to notify third parties. Where applicable You have the right to request the PUBGALAXY to notify third parties regarding the rectification, erasure or restriction of the processing of Your personal data when PUBGALAXY has provided Your data to them.

9.7. Right of data portability. You have the right to receive the personal data You have provided, and which are related to You in a structured, commonly used, machine-readable format, and to use such data with another controller at your discretion.

9.8. The right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects concerning You or similarly significantly affects You unless there are grounds provided for in the applicable data protection legislation, as well as appropriate safeguards to protect your rights, freedoms and legitimate interests. No technology falling within this category is used for the provision of the Services.

9.9. Right to withdraw consent. You have the right to withdraw at any time your consent for personal data processing based on prior given consent. Such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

9.10. Right to object. You have the right to object, in respect to data processed, on the basis of legitimate interest. In the event of such an objection We will examine your request and, if justified We will comply with it. If We believe there is sufficient legal grounds for the processing or where necessary for establishing, exercising or defending legal claims We will inform You accordingly.

9.11. Exercise of rightsYou can exercise these rights at any time by sending us a notice via the following email address: privacy@pubgalaxy.com.

9.12. Right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with a supervisory authority if You consider that the processing of personal data concerning You infringes on the applicable data protection legislation. The supervisory authority in the Republic of Bulgaria is the Commission of Personal Data Protection, address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.

Your PUBGALAXY Team!