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PRIVACY POLICY FOR SERVICES PROVIDED BY SUNMEDIA

VLN SERVICIOS PUBLICITARIOS INTEGRALES, S.L. (hereinafter, “SUNMEDIA”) with VAT number ESB87495628, and registered office in Madrid, Príncipe de Vergara, 112 - 3ª Planta 28002; privacy policy clearly explains how SUNMEDIA processes personal data obtained from its commercial partners, acting as Data Procesor, in order to be able to be able to provide its services. Hereinafter we will describe how do we provide our services and also our products and services allow its customers to buy advertising spaces on line and to use our analysis and measure products.

COLLECTION AND PURPOSES OF PERSONAL DATA PROCESSING.

Whenever the final user visits any of our partner´s sites or any on line add, we assign such user a user unique identifier (a random and unique combination of characters), “cookie”.

Something similar occurs whenever a user watch or interact with an on line add which has been place by SUNMEDIA.

The purpose of processing the data we collect is to offer the best advertising campaigns to each user, campaigns that are of their interest, in order to be able to be accurate, SUNMEDIA needs to collect certain information. However, SUNMEDIA will not proceed to sale data to any third party without the express authorization of the owners of the data.

SUNMEDIA collects information regarding end user´s devices behavior. There are different ways to obtain user and device information, and they might vary depending on the device and the environment. The information that we might collect, process or share also varies according to the collaborator with whom we are working with and the object of the contract that we have signed with each one of them.

Please find below and explanation of some of the personal data to which we might have access to:

What data do we not collect?

SUNMEDIA, as indicated in this section, does not treat personal data of sensitive categories, only identifiable user data.

SUNMEDIA does not have segments targeted at children under 13 years of age

SUNMEDIA does not collect any impression-level data through the ad that will be used for subsequent ad targeting

SUNMEDIA does do not use hyperlocal geotargeting (especially with mobile ads via GPS)

SUNMEDIA does do not use browser packet-sniffing (reading packets of information from the HTTP request)

SUNMEDIA does not perform browser/device fingerprinting

Which purposes we do not use personal data for?

End users will not be identified in order to know who they are.

SUNMEDIA does not use scanning information reading packets (browser packages of the HTTP request) that allows it to collect user data.

SUNMEDIA does not use any Flash cookies/LSOs (HTTP/browser cookies only)

SUNMEDIA does not assist or knowingly permit any 3rd party to set a cookie, or alter/delete a cookie set, on any Google Owned and Operated domains (e.g. on the DoubleClick domain).

SUNMEDIA does not perform impression-level page scraping

PERSONAL DATA RECIPIENT

Personal data collected in the provision of services will not be transferred to other people or companies to be used for their own purposes.

SUNMEDIA does not share cross-client data (clients of licensed technologies need to own data collected from campaigns and licensed tech vendors can only use aggregated data for system improvements).

However, SUNMEDIA will disclose to the competent public authorities the Personal Data and any other information that is in its power or accessible through its systems and is required in accordance with the legal and regulatory provisions applicable to the case.

Likewise, personal data may be shared with other companies that will be under-charged with the processing of their data. You can find an updated list of the sub-processors with which SunMedia collaborates here:

Subprocessors shall (i) agree in writing to process data according to the instructions provided by the owner of the data and/or the data controller, (ii) to implement appropriate technical and organizational measures to protect the data against any possible security breaches (iii) to ensure full compliance with RGPD requirements.

STORAGE PERIOD

Personal data will be kept for attend the purposes mentioned above based on your consent. Once your consent is revoke SUNMEDIA will keep the personal data duly blocked for a period of 5 years with the sole purpose of attending to any type of responsibilities that may arise. Once prescribed such responsibilities, your personal data will be delete.

USERS RIGHTS

Any User who wishes to exercise his or her rights of access, rectification, erasure, restriction of the processing, to data portability or of objection must notify SUNMEDIA upon written request send to the email address:gdpr@sunmedia.com. In accordance with GDPR provisions, the contents of the rights that Users are entitled to are the following: Right of access, Right to rectification, Right to erasure. Right of objection, Right to restrict the processing, Right to data portability and Right to file a complaint before the relevant Supervisory Authority.

SECURITY MEASSURES

SUNMEDIA will treat your personal data in an absolutely confidential way. Likewise, SUNMEDIA has implemented adequate technical and organizational measures to guarantee the security of its personal data and to prevent its destruction, loss, illegal access or unlawful alteration. When determining these measures, criteria such as the scope, context and purposes of the treatment and the existing risks have been taken into account. SUNMEDIA guarantees the following security measures:

SUNMEDIA is not responsible for any third parties ‘security meassures, for example, its partners. For more information about their practices regarding the collection and process of personal data, you should consult their privacy policies.

SUNMEDIA does not authorize any third party to install, alter or delete cookies in any domain owned and operated by third parties, including but not limited to, Google Inc.

SUNMEDIA does not use any Flash / LSO cookie (only HTTP / browser cookies).

HOW TO AVOID YOUR PERSONAL DATA TO BE COLLECT AND/OR PROCESS?

You can change the preferences of your browser to choose which cookies it must allow access to. These preferences are usually in the menu "options" or "preferences" of your browser. You can find more information here, or in the menu "Help" of your browser:

However, if you change your preferences and block these cookies, some functions of our Website will be annulled and you will not be able to make the most of the features from our Website.