Privacy Policy

Marketcom Technology Limited and its subsidiaries (referred to as “Marketcom”, “we”, “our” or “us”) provide a wide range of eCommerce platforms and built-in marketing solutions, including digital and programmatic advertising solutions.

This privacy policy explains how we may use any personal information we hold in relation to you (the “user”) in connection with our advertising solutions and platforms. Publishers and advertisers with whom Marketcom has a commercial relationship are referred to as “Marketcom Customers” in this policy. We collect personal information in the following four ways:

For the purposes of applicable data protection laws, including the EU General Data Protection Regulation, as amended and supplemented (the “Data Protection Laws”), Marketcom is a “controller” of personal information. If you have any questions relating to this privacy policy or our use of personal information, please contact us using the information in Section 12 below.

1. PERSONAL INFORMATION WE MAY COLLECT DIRECTLY FROM YOU

Glispa Discover

If Glispa Discover software has been pre-installed on your device, we will collect limited amounts of personal information about you, including:

We use this information to provide and improve Marketcom’s services, including for:

When you contact us

If you contact us by telephone, email, post or using any other function offered by our website, we may collect your name, contact details, employer details, location and any other information that you provide to us.

We will use this information to review, investigate and respond to your questions or comments as necessary. Please note that we may record telephone calls made to us.

When you register with us

If you register with us as a publisher or advertiser, or as a customer of Glispa Create, we will collect your name, contact details, employer information (if relevant), payment information, tax registration number.

We will use this information to:

If we need to verify your identity

In some circumstances we may be required by law or by our internal compliance procedures to take steps to verify the identity of the owners or companies officers of companies that we do business with. These checks are sometimes called “know your client” or “KYC” checks. As part of this process we will ask relevant individuals to provide certain information such as name, address and nationality. We will also ask for documentary evidence verifying these details, such as a copy of the individual’s passport and/or utility bill.

We will use the information that provided us for the purpose of complying with our legal or internal compliance obligations. Our legal basis for processing this personal information is that it is necessary for compliance with a legal obligation to which we are subject, alternatively that it is necessary for our legitimate interests in ensuring that we are conducting our business in a responsible way which complies with our internal standards.

2. PERSONAL INFORMATION WE MAY COLLECT FROM THIRD PARTIES

Glispa Perform

If you interact with a website or app that uses Glispa Perform, we may receive limited amounts of personal information about you, including:

We use this information to provide and improve Marketcom’s services, including for:

myDSP

If you interact with a website or app that uses myDSP, we may receive limited amounts of personal information about you, including:

We use this information to provide and improve Marketcom’s services, including for:

We obtain such information by using digital identifiers. You can find more information on our digital identifiers below:

Third Party Service Providers

We also work closely with third party service providers including, for example, business partners, sub-contractors, advertising networks, analytics providers and search information providers (“Third Party Service Providers”).

We may receive information about you from Third Party Service Providers such as Google Analytics. We may share some of the information we collect from you with Third Party Service Providers (see “Disclosure of Your Information” below).

3. PERSONAL INFORMATION WE AUTOMATICALLY COLLECT

When you use our website, we may automatically collect information including:

4. OPT OUT

To opt out of personalized ads served in apps on your mobile device, follow the instructions below.

If you have an Android device:

  1. Find Google Settings. Depending on your device, it could be located:
    1. in a separate app called “Google Settings”, or
    2. in your main “Settings” app, scroll down and tap “Google”
  2. Tap “Ads”
  3. Switch on “Opt out of interest-based ads”

If you have an iOS device:

You can opt out of interest-based advertising by updating to iOS 6.0 or higher, and setting “Limit Ad Tracking” to ‘ON. You can do this by clicking on Settings - > General - > About - > Advertising and toggling “Limit Ad Tracking” to ‘ON.

When you have opted out using these settings on a device, Marketcom will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests. Marketcom requires its partners to honor opt-out preferences expressed using these controls. However, please note that opting-out using these settings would only prevent serving tailored ads to you; this would not affect other activities, such as serving contextual advertising, ad frequency capping and analytics.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/choices, or www.youronlinechoices.eu and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics by following this link: https://tools.google.com/dlpage/gaoptout

5. OUR LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION

Our legitimate business interests

If we have collected your personal information directly from your device, or if it has been provided to us by a publisher or advertiser, our legal basis for using your personal information is that it is necessary for our legitimate interests in conducting our business and facilitating the serving of adverts.

If you are a publisher or advertiser, or an employee of a publisher or advertiser, and we have collected your information in the course of our commercial relationship or in order to market to you, our legal basis for processing your personal information is that it is necessary for our legitimate interest in performing the contract between us and the business you are associated with.

Consent

We may collect personal information from you or receive it from Marketcom Customers where you gave your consent to do so. Marketcom Customers collect this consent on our behalf.

6. DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any member of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, from time to time (our “group”).

We may share your information with selected third parties including:

We may disclose your personal information to third parties:

We do not sell, trade, or rent your personal information to others.

7. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

The personal information that we collect from you will be transmitted to third parties located in countries outside of the European Economic Area (“EEA”) including the United States and Israel.

If you would like more information about how your personal information is transferred, and the safeguards applied, please contact us at contact@market.com.

8. RETENTION OF YOUR PERSONAL INFORMATION

The period for which we will retain your personal information will vary depending on the purposes it was collected for, as well as the requirements of any applicable law or regulation.

For example, if you engage our services, we will store your personal information and details about your order for as long as is necessary to comply with applicable tax legislation, and for the period for which you or we could bring legal proceedings in relation to the services.

9. YOUR RIGHTS

You may have certain rights in relation to the personal information we collect about you. These may include the right to request access to the data we hold about you, or to obtain a copy of the personal information in machine readable format, to request that it is erased or that any inaccurate personal information is rectified. You may also have the right to ask us to restrict how we process your personal information or to withdraw your consent to how we process your personal information. Please contact contact@market.com if you would like to make a request.

You also have the right to complain about the use of your personal data to the supervisory authority of your habitual residence, place of work or of an alleged infringement of the EU General Data Protection Regulation.

A summary and further details about your rights under EU Data Protection Laws, is available on the EU Commission's website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

10. THIRD PARTY WEBSITES

The website may, from time to time, contain links to and from the websites of our partners, affiliates, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content on these websites and We are not responsible for the practices employed by them. If you follow a link to any of these websites, please note that these websites have their own privacy and customer support policies and we do not accept any responsibility or liability for these policies. Please carefully check these policies before you submit any personal information to these websites.

11. CHANGES TO OUR POLICY

This policy will be reviewed from time to time to take account of changes to our operations and practices. If we make changes, we will notify you by revising the date at the top of this policy, and if the changes are significant, we may provide you with additional notice, such as adding a statement to the homepage of the website or sending you an email with the update. Any personal information held will be governed by our most current policy.

12. CONTACT US

If you have any questions or requests regarding this privacy policy, the practices of the website or your dealings with the website, please contact contact@market.com