I. General information

1. In this Privacy Policy terms “we”, “us” and “our” should refer to Online Advertising Network sp. z o.o. with its registered office in Warsaw (05-075), ul. Żeromskiego 7, entered into the register of entrepreneurs of the National Court Register, maintained by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under number 0000691949, NIP (Taxpayer Identification Number): 9522167057, REGON (Statistical Number) 368128657.
2. This Privacy Policy is binding exclusively in relation to advertising services provided by Online Advertising Network sp. z o.o. over the Internet. Those advertising services include, but are not limited to, interest-based advertising, including retargeting.
3. Whenever necessary you can contact us traditionally by writing to the address of our headquarter (indicated in point 1) above), by e-mail: team@oan.pl and by phone: 00 48 22 535 30 50.
4. In any case related to processing of data as described in this Privacy Policy please contact us at: privacy@oan.pl.

II. Collected and processed data

1. In this section we have set out:
   1. the general categories of data that we process;
   2. the source and specific categories of data;
   3. the purposes for which we process data for;
   4. the legal bases of the processing.
2. We process information about your use of services we render and services that are provided by our clients. This information is not personal data (“usage data”). The usage data may include information such as:
   1. numbers of users requesting services managed by us and our partners, along with time and duration of visits,
   2. numbers of users displaying our advertisements, along with amount of impressions and clicks they generated,
   3. data of effectiveness of our advertisements, including categories and profiles, to which users have been assigned to,
   4. technical data of users’ web browsers and operating systems,
   5. regional settings and approximate location,
   6. anonymized IP addresses.
3. The source of the usage data is our analytics system or our partners’ systems. You may find the list of partners in section II.13 below.
4. This usage data may be processed by us and our Partners indicated in section II.13 below for the purposes of analyzing the use of the services and, optionally, linking devices, selecting basic ads, creating a personalised ads profile and selecting personalised ads (ad targeting), measuring ads performance, applying market research to generate audience insights (users’ modelling), developing and improving products (R&D) based on user’s consent as well as technically delivering ads based on our legitimate interests, namely advertising services of ours or of our clients’. Additionally, we may process data in order to ensure security, prevent fraud and debug when necessary, which also constitutes our legitimate interest.
5. We will take reasonable steps to ensure that end user is provided with clear and comprehensive information about, and gives consent to, the storing and accessing of cookies and other information on the end user’s device where such activity occurs and where providing such information and obtaining such consent is required by law.
6. We collect usage data in order to increase the relevancy of the ads being displayed to you i.e. advertisements of products they may be likely interested it, and other advertising-related purposes. Estimation of advertisements which may be of interest to a user is made by checking past browsing behavior of a user based on a cookie stored by the user’s web browser, and by assigning the user to one or more categories. Information collected through ads are also used for subsequent use in targeting or re-marketing. Statistical information about users and effectiveness of advertisements may be passed to our customers – advertisers, in order to allow them to make informed decisions regarding their advertising campaigns and assess their effectiveness. Information may be also passed to third parties if it is technically required to display advertisements to users. We will also pass data if required by applicable law.
7. The usage data we collect is also used for reporting purposes, to give our clients and partners more information about the performance of their advertising campaigns, and to improve performance over time.
8. We do not collect, use and process any personal data, including personal data of users such as name, gender, age, address, place of residence, personal identification numbers, phone numbers, e-mail etc. Also, we do not receive any additional data from our partners, which, along with data collected by our technology, would enable us to directly identify you.
9. We do not collect, use and process the data from users known to us to be under the age of 16 years, any data from websites directed to children.
10. We do not collect, use and process sensitive data (such as data about political opinion, religion, health etc.).
11. The usage data do not directly identify an individual and is not considered to be personal information, however specific types of the information such as non-anonymized IP address, mobile Advertising IDs or cookies file, may be considered personal information in EU/EEA or if combined with other information. If such information may be considered personal information we treat this information as personal information.
12. If we or our client or partner obtain personal data and has no legal basis for the access to and processing of that data, we or our client or partner should quickly cease collection and storage of the data and refrain from passing the data on to other parties, even if those parties have a legal basis.
13. We may exchange the usage data with third parties including:
    1. Agencies such as:
       1. Omnicom Media Group https://omnicommediagroup.com/privacy-notice/
       2. Xaxis https://www.xaxis.com/privacy-notice/
    2. DMP partners, including the following entities:
       1. Adobe https://www.adobe.com/pl/privacy/policy.html
       2. Eyeota https://www.eyeota.com/privacy-policy/
       3. Liveramp https://liveramp.com/privacy/
       4. Lotame https://www.lotame.com/about-lotame/privacy/
       5. Nielsen https://www.nielsen.com/pl/legal/privacy-principles/
       6. Oracle https://www.oracle.com/legal/privacy/marketing-cloud-data-cloud-privacy-policy.html
       7. AdSquare https://www.adsquare.com/privacy/
       8. Zeotap Gmbh https://zeotap.com/product-privacy-policy/
    3. DSP partners, including the following entities:
       1. Adform https://site.adform.com/privacy-center/overview/
       2. AppNexus https://www.appnexus.com/platform-privacy-policy
       3. BidTheatre https://www.bidtheatre.com/privacy-policy
       4. Google https://policies.google.com/privacy?gl=pl
       5. MediaMath https://www.mediamath.com/privacy-policy/
       6. The Tradedesk https://www.thetradedesk.com/general/privacy
    4. SSP partners, including the following entities:
       1. AdOcean https://adocean-global.com/pl/company/privacy-policy/
       2. AdThink https://adthink.com/terms/privacy/
       3. ADX https://www.adx.ae/English/Pages/privacypolicy.aspxs
       4. Appnexus https://www.appnexus.com/platform-privacy-policy
       5. Bidswitch https://www.bidswitch.com/privacy-policy/
       6. Epom https://epom.com/privacy-policy
       7. Exoclick https://www.exoclick.com/privacy-and-cookies-policy/
       8. Gamoshi https://www.gamoshi.com/privacy-policy
       9. GothamAds https://gothamads.com/privacy-policy
       10. iBillboard http://www.ibillboard.com/scripts/block/cookies_and_privacy_en.php
       11. Improve Digital https://www.improvedigital.com/privacy-policy/
       12. OpenX https://www.openx.com/legal/privacy-policy/
       13. Pubmatic https://pubmatic.com/legal/privacy-policy/
       14. Pulsepoint https://www.pulsepoint.com/legal/platform-privacy-policy
       15. Smart Ad Server
       16. Stroer https://www.stroeer.com/en/service/privacy-policy.html
    5. and other entities to which we provide our services and entities providing services to us, such as our tech providers. We underline that we never share any personal data, we may only share usage data. Please consider checking the privacy policies of the above entities.
14. We may share the data collected within the capital group including OnAudience Ltd, OnProspects, The Linea1 MKT S.L., Cloud Technologies S.A.
15. We follow the IAB Transparency & Consent 2.0 framework (https://iabeurope.eu/tcf-2-0/).

III. Cookies and other technical means

1. We are storing on users’ computer systems telephone or other device from which you access cookie files (small text files) containing anonymous identifier (alphanumerical).
2. We are also using other technical means necessary to provide its advertising services, such as tracking pixels (accessing cookie files) and mobile identifiers.
3. Cookie files:
   1. collect data regarding your use of the website, and their main purpose is to facilitate the use of the website and customize the website to your needs and expectations;
   2. are placed on the user’s end device and may also be placed on behalf advertisers and partners cooperating with us;
   3. do not store information constituting personal data of the user;
   4. are not used to determine the identity of the user;
   5. are used on the website, based on the acceptance of recommended settings of the website user expressed through appropriate software settings, in particular through a web browser.
4. You may at any time revoke or change the scope of any previously expressed consent to use cookie files on the website and delete them from your browser.
5. You may also at any time limit or disable cookie files in your browser through the settings. In this case, however, your use of the website may be less efficient, you may not have access to certain content or be able to use some of the website’s functionalities, and in extreme cases the correct display of the website pages may be completely blocked.
6. We will retain cookie files for a maximum period of 12 months. Please refer to our partners’ privacy policies for more information on our partners’ retention period.
7. We use the following types of cookies:
   1. ID cookies: these are cookies that remember an anonymous identifier that we have assigned to you
   2. Technical cookies: these are cookies that are saved when our partner is allowed to set their own cookie on our coverage.

IV. Opting out

1. You may prevent data collection, processing and transmission to third parties by downloading and storing a following cookie in https://oan.pl/opt-out a web browser it is using. If you are using more than one web browser or more than one computer system, a cookie must be downloaded and stored in each of the browsers. Clearing a browser’s cache from cookies will require re-downloading of an opt-out cookie. Downloading an opt-out cookie is equivalent to using “Do not sell my personal data” functionality as required by the CCPA (California Consumer Privacy Act).
2. You may also disable cookies and local storage in its web browser. However, it will hinder web browsing experience, as many websites are using cookies to store user preferences.

V. Your rights

1. You are entitled to:
   1. 1. the right to access your data and receive a copy thereof, i.e. obtain information whether we process your personal data and specific information about such processing;
      2. the right to rectify (amend) their data, i.e. request to amend inaccurate personal data;
      3. the right to delete data, restrict the processing of data, provided that one of relevant ground for such action apply;
      4. the right to object to data processing;
      5. the right to data transfer, i.e. receive data you provided us with in a structured, commonly used and machine-readable format and if necessary to request transmitting those data to another controller;
      6. the right to complain to a supervisory authority;

   and the right to withdraw consent.

• If you consider that our processing of your information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
• To the extent that the legal basis for our processing of your information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
• You may exercise any of your rights in relation to your personal data by written or e-mail notice to us as indicated in Section 1.

VI. International transfers of your personal data

1. Should the relationship with one of our clients or partners involve cross-border data flows outside the European Union, our partner shall formally undertake to comply with the best data protection standards set out by GDPR.

VII. Retaining and deleting personal data

1. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of data.
2. If we are the data processor of your personal data that we process in accordance with the data controller’s instructions such data shall not be kept for longer than specified by the data controller.
3. If we are the data processor of your personal data we will retain your personal data for a minimum period of 12 months following your subscription.
4. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation.
5. Usage data are not personal data and may be stored up to 24 months.

VIII. Amendments

1. We may update this policy from time to time by publishing a latest version on our website. A new policy enters into force immediately after its publication on the website.
2. We will inform you of any such changes via email notification or notification on our website.