This Privacy Policy forms an integral part of General Terms of Service. Any term used in this Privacy Policy not explicitly defined herein shall be interpreted according to the General Terms of Services. 

Who are we?  

We are Leadgenia s.r.o., company registered in the commercial register maintained by the Municipal Court Prague, Section C 247987, identification number 04458206, with its registered seat at
Příčná 1892/4, 110 00 Praha, Czech republic (hereinafter referred to as the “Provider” or „we“).

Why do we may need to process your personal data? 

We provide our customers (hereinafter referred to as the “Tenant”) a web-based application that shall be used for tracking Tenant’s advertising activities in the area of affiliate marketing business (hereinafter referred to as the “Application”), primarily, but not only, to help to market Tenant’s services or products online on third parties websites by advertisements (those third parties hereinafter also referred to as the “Affiliates”). To be able to do so we need to process some personal data. Whether, and to what extent, we will process personal data may depend on a package of services selected by the Tenant. We will only process personal data if necessary for the performance of our contract or in order to take steps at your request prior to entering into a contract with us. The Provider may also retain personal data in order to meet relevant legal requirements, above all, but not limited to requirements arising from accounting and tax legislation. 

What does GDPR mean? 

GDPR stands for Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. GDPR represents the legal framework for the protection of personal data in the European area and directly establishes the rules for the processing of personal data. The Provider is governed by the GDPR rules in his activities and is compliant with the GDPR. 

What personal data we may have access to? 

The Provider needs access to names and email addresses of all physical individuals accessing the Application on behalf of the respective Tenant (end users) in order to be able to identify them and register them in the Application. The Provider will also store the information about the country of origin. The personal data shall be collected and provided to the Provider by the Tenant as the controller of the personal data, the Provider considers himself to be the processor only. Tenants determine the data that they collect and provide to the Provider, that process shall be governed by Tenant’s own privacy policies and applicable regulations. 

The Provider shall also obtain contact phone number and billing details from the Tenant which may also (partially or fully) consist of information subject to personal data protection. 

Based on Tenant’s instruction (as a data controller) the Provider may also collect IP addresses and cookies from end user devices in order to manage and measure Tenant’s marketing activities via the Application. Additionally, based on Tenant’s instruction, the Provider may also manage Tenant’s email contact list used for business communication with Affiliates via the Application and Affiliates` billing details.

The Provider will not process special categories of personal data pursuant to Article 9 of GDPR.

For more information about cookies please see the Provider’s separate document “Cookies declaration”

How do we protect personal data? 

Taking into account the state of the art, the nature, scope, context and purposes of processing personal data as well as other factors, the Provider has implemented appropriate technical and organizational measures in order to ensure the level of security appropriate to relevant identified risks. 

The Provider shall always process personal data only lawfully, fairly and in a transparent manner in relation to the data subject. Personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. The scope of personal data collected shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The Provider may use a third party to further process some personal data, especially technical partners. In such a case the Provider will announce relevant information about such a partner on his website www.paldock.com. The Provider shall store any personal data within the Tenant’s region, be it the European Union or the United States.

How long will we have access to personal data?

The Provider processes personal data for the purpose of performance of the contract with the respective Tenant, therefore the Provider will process the personal data for the entire duration of the contract. The Provider may retain the personal data for a limited period of time after the termination of cooperation with the respective Tenant if required by law (above all, but not only to fulfill the requirement of relevant tax legislation) or if necessary to resolve disputes, enforce agreements and/or to comply with other legal obligations.  

What are your rights regarding your personal data?

We always process personal data in a transparent and correct manner and in accordance with the legal requirements. However, at the same time you have the right to contact us in order to obtain information about your personal data processing or to exercise the rights that are related to personal details. Above all, but not only you have the right to obtain the copy of your personal data processed by the Provider, you have the right to request an update of your personal data if you believe them to be inaccurate, you have a right to request from us the erasure of your personal data if they are no longer required for the purpose for which they were processed. You have a right to data portability. You have a right to object to the processing of your data. 

You have a right to file a complaint with the supervisory authority (Office for Personal Data Protection) should you think that the rules of personal data protection were breached during the processing of your personal data. 

Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz 

For more information about the Provider’s data protection processes please contact us anytime at dpo@paldock.com.